The courts found in the Felixstowe Dock and FCE Bank cases that denying the group relief between two UK resident companies was not in line with the Tax Treaty non-discrimination provision where the UK companies were held through a non-UK parent. Both cases concerned group relief between UK companies – cross border group relief was not claimed.
Following the 2010 London and the 2011 Paris cups, the third RSM Europe football tournament was back in town in Amsterdam this year. And so rightly it was back in town. I mean, we had a brilliant opportunity to share every inch, every second, every minute of a long, sporting day with ladies and gentlemen of our own breed: the smart and kind of the RSM network.