Marks & Spencer: UK Government Cut Their Losses

On February 21, 2006, the London office authored an Alert Memorandum entitled “Marks & Spencer: UK Government Cut Their Losses.” This three-page memo discusses the announcement of HM Revenue & Customs on how they will interpret the decision of the ECJ in December 2005, which stated that in certain limited cases losses incurred by EU subsidiaries of a UK company may be set against the profits of the UK parent company under the UK’s group relief rules. The memorandum briefly summarizes some of the key points in the announcement.