問(wèn)題: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.
  答案:The correct answer is: Losses in Lithuania only.
  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.