Corporation Tax: Consortium relief: residency of link company | Practical Law

Corporation Tax: Consortium relief: residency of link company | Practical Law

The European Court of Justice has held that limiting consortium relief to cases where the link company is a UK company breaches both the freedom of establishment and the free movement of capital provisions of the Treaty on the Functioning of the European Union, irrespective of the residence of the companies that own that link company.

Corporation Tax: Consortium relief: residency of link company

Practical Law UK Articles 2-565-4946 (Approx. 3 pages)

Corporation Tax: Consortium relief: residency of link company

by Norton Rose Fulbright LLP
Published on 24 Apr 2014European Union, United Kingdom
The European Court of Justice has held that limiting consortium relief to cases where the link company is a UK company breaches both the freedom of establishment and the free movement of capital provisions of the Treaty on the Functioning of the European Union, irrespective of the residence of the companies that own that link company.