Esso Exploration and Production UK Ltd and Others v Revenue and Customs (Procedure : Other): FTTTx 4 Mar 2020

CORPORATION TAX – Cross Border Group Relief for losses – Schedule 18 FA 1988 – Marks and Spencer exception – Holmen and Memira – UK/USA Double Taxation Conventions – OECD commentaries – sister EU companies – Felixstowe and Philips – US ultimate parent – FCE – Boake Allen – no possibilities test – impact of domestic law – appeal dismissed

Citations:

[2020] UKFTT 139 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 05 November 2022; Ref: scu.649204