Irish Court of Appeal Holds Subsidiaries of Fiscally Transparent U.S. Entity Not Eligible for Group Loss Relief

The Irish Court of Appeal delivered a judgment on 27 May 2025 on whether the subsidiaries of a fiscally transparent U.S. Entity are eligible for group (loss) relief under Irish law. This case involved an appeal by Susquehanna International Securities Limited and Susquehanna International Group Limited (the Taxpayers) against a High Court judgment that had overturned a Tax Appeals Commission determination. The core dispute centered on the denial of group relief claimed by the Taxpayers under …