Kessler, Wolfgang; Eicke, Rolf - Universität <Freiburg, Breisgau> / Lehrstuhl für … - 2008
tax law. Others call the case‘‘Marks & Spencer revisited on the branch level.’’ In fact,both statements are correct. The … question is whetherthe country of the head office must take into accountlosses of a foreign branch, even though the … applicabledouble taxation convention provides for an exemptionof the branch profits in that country. Contrary to Marks& Spencer (C-446 …