Marks & Spencer plc v Revenue and Customs Commissioners (No 2) [2014] UKSC 11; [2014] WLR (D) 90
‘A company was entitled to make successive claims to cross-border group relief against corporation tax in relation to the same loss incurred in the same accounting period by a European subsidiary which had gone into liquidation and then to withdraw any earlier claims in respect of the same surrendered loss which did not meet the subsequent judicially determined test, subject to the claim ultimately relied upon not being statute-barred.’
WLR Daily, 19th February 2014
Source: www.iclr.co.uk