Marks & Spencer plc v Halsey (HMIT) (2002) Sp C 352
[A reference to the ECJ from this decision is reported at  BTC 318.]
Dr John F Avery Jones, Malcolm Gammie QC.
Decision released 17 December 2002.
Corporation tax – Group relief – Losses arising in French, Belgian and German subsidiaries of UK company – UK provisions denying group relief for losses – Whether UK provisions contrary to Community law – Income and Corporation Taxes Act 1988, s. 402(3A), (3B), 403D(1)(a), 413(5) – Article 43 EC.