<b>Tax News:</b> HMRC close down group relief loophole. By Nichola Ross Martin

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Following the judgment of the European Court of Justice in December 2005 in the case of Marks & Spencer Plc v David Halsey Case C-446/03, H M Revenue and Customs have announced changes to group relief for losses.

The court found that Mark & Spenser was allowed to offset losses from group companies resident in other member states against profits earned in the UK. The Revenue considers that this interpretation will open the doors to creative tax avoidance schemes. Tax advisors are once again blamed as the villains of the piece, rather than the companies who are trying to mitigate their tax liabilities. The announcement goes on to say:

'It has come to the Government's attention that some tax advisers have been suggesting that groups that have loss-making companies resident in another Sta...

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