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Marks and Spencer PLC v Commissioners for HM Revenue and Customs – First-Tier Tribunal (Tax)

EUROPEAN LAW – group relief for losses of non-resident subsidiaries – whether there are no possibilities for those losses to be taken into account at the date of the group relief claim – no at the date of the original claims which are not valid claims, and yes on 20 March 2007 when the second claims were made — appeals allowed in principle

Nicola Shaw appeared for the Appellant

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