Question：P Ltd has three wholly owned subsidiaries.
P Ltd operates overseas, via a permanent establishment in Lithuania, and a wholly owned overseas resident subsidiary in New Zealand.
Both overseas operations are making losses.
Which of these losses may be set against P Ltd's profits?
A. Losses in Lithuania only.
B. Both.
C. Losses in New Zealand only.
D. Neither.
The correct answer is:A
The losses of overseas permanent establishments are treated as the losses of the UK company.
There is no relief against the UK parent's profits for any overseas losses of a non-resident subsidiary not based within the EEA.
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