|Source:||All England Reporter|
|Publisher Citation:|| All ER (D) 129 (Apr)|
|Neutral Citation:|| EWHC 811 (Ch)|
|Representation||Graham Aaronson QC and Paul Farmer (instructed by Dorsey & Whitney) for the appellant.|
|Richard Plender QC and David Ewart (instructed by the Solicitor for Revenue and Customs.|
|Judgment Dates:||10 April 2006|
Corporation tax - Company - Group relief - Profits of parent companies - Deduction of losses incurred by resident subsidiary allowed by national law - Deduction of losses incurred in another member state by non-resident subsidiary not allowed - Whether provisions of contrary to Community law - Case referred to Court of Justice of European Communities for preliminary ruling - Application of Court's judgment to facts.