A recent decision of the Administrative Court of Appeal of Versailles has been published regarding the offset of definitive losses of a permanent establishment (branch) in Luxembourg by a French group. The case involved a French group parented by Financière SPIE Batignolles (FSB) SCA, which was solely liable for the tax due by the group. In December 2016, FSB requested the allocation of the definitive loss of a Luxembourg branch to the results of one of its subsidiaries for the financial yea…