ECJ Freedom of establishment Direct taxation Taking account of losses incurred by a permanent establishment situated in a Member State and belonging to a company which has its registered office in another Member State
Judges:
K Lenaerts, P
Citations:
[2008] EUECJ C-414/06, [2008] STC 3229, [2008] 3 CMLR 2, [2008] ECR I-3601, [2008] STI 1359, [2008] CEC 1049, C-414/06
Links:
Jurisdiction:
European
Citing:
Opinion – Lidl Belgium GmbH and Co KG v Finanzamt Heilbronn ECJ 14-Feb-2008
ECJ Opinion – Freedom of establishment – Taxation of companies – Company established in one Member State with a permanent establishment in another Member State – Loss made by the permanent establishment. . .
Cited by:
Cited – Revenue and Customs v Marks and Spencer Plc SC 22-May-2013
The company wished to assign losses in its European subsidiaries against its profits. Since the losses were first claimed, the subsidiaries had gone into insolvent liquidation.
Held: Lord Hope said: ‘I would answer the first issue by rejecting . .
Lists of cited by and citing cases may be incomplete.
Corporation Tax
Updated: 30 November 2022; Ref: scu.518023
