Interesting diagram. But are you sure you can’t relieve losses across EU borders?
It is theoretically possible, but not in this instance.
The main case is the M&S case. That, I think, led to the principle that losses could be relieved if they weren’t able to be relieved in any other way.
In the Autumn Statement there were some amendments for allowing losses to be transferred from permanent establishments, but this is related to the branch rules I think. I’ll post a link shortly to that, which explains the rules for branches.
And the fact is, Starbucks accounts don’t show an adjustment for group relief, which they should if they had group relieved losses.
I haven’t looked at in depth – but Philips CJEU case might hold more background info if you can access it.
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