On 3 February 2015, the Court of Justice of the European Union (CJEU) issued its decision finding that the UK's rules on cross border group relief are compatible with EU Law, dismissing a European Commission challenge. Under the UK rules, group companies are allowed to offset profits and losses among themselves. However, the losses of non-resident group members may only offset profits of a resident group member when the loses are definitive, i.e. there is no possibility of the loss being taken into account for the non-resident in previous, current or future periods. Prior to 2006, the UK rules did...