Marks & Spencer plc v Halsey (HM Inspector of Taxes)

Subject Matter

REVENUE — Corporation tax — Group relief — Parent companies and subsidiaries of different member states — Losses by subsidiary established in member state of parent's establishment deductible from parent's profits — Losses by subsidiary in another member state not deductible — Whether contrary to freedom of establishment — EC Treaty, arts 43EC, 48EC

(Case C-446/03); [2006] Ch 184; [2006] 2 WLR 250