ECJ to rule on denial of deduction for currency loss on start-up capital granted to a foreign branch

The European Court of Justice is expected to issue a decision in the case of Deutsche Shell GmbH v. Finanzamt für Grossunternehmen in Hamburg. In that case, the Tax Court of Hamburg considered whether, in computing German tax liability, the denial of a deduction for currency losses on start-up capital granted to a foreign branch, constitutes a violation of the freedom of establishment.