ECJ Opinion – Interpretation of Articles 43 EC and 48 EC – Freedom of establishment – Tax legislation – Corporation tax – Tax relief – Consortium claim for group relief (consortium relief) – National legislation excluding the transfer of losses within the national territory by one consortium company to another company belonging to a company group to which a ‘link company’ that is also a member of the consortium belongs – Residence requirement imposed on the link company – Discrimination according to the place of the corporate seat – Ultimate parent in third country – Corporate ties passing through third countries
Jaaskinen AG
C-80/12, [2013] EUECJ C-80/12
Bailii
European
Citing:
Reference – The Felixstowe Dock and Railway Company Ltd and Others v Revenue and Customs FTTTx 19-Dec-2011
Corporation tax – joint referral – FA 1998, Sch 18, para 31A – group relief – consortium – surrendering company indirectly partly owned by Luxembourg company – condition that ‘link company’ must be UK resident or carry on a trade in the UK through a . .
Cited by:
Opinion – Felixstowe Dock And Railway Company Ltd v The Commissioners For Her Majesty’s Revenue And Customs ECJ 1-Apr-2014
Judgment – Reference for a preliminary ruling – Freedom of establishment – Corporation tax – Tax relief – Groups of companies and consortia – National legislation permitting losses to be transferred between a company belonging to a consortium and a . .
Lists of cited by and citing cases may be incomplete.
Corporation Tax
Updated: 01 November 2021; Ref: scu.516981