In a recent opinion, C.J.E.U. Advocate General Juliane Kokott suggested that the terms used in the landmark Marks and Spencer decision should now be abandoned. Marks and Spencer involved U.K. group relief legislation that, among other things, allowed a U.K. group parent company to offset the losses of its U.K. subsidiaries against the parent’s profits. Stanley C. Ruchelman, Fanny Karaman, and Rusudan Shervashidze contemplate the future of U.K. group relief in light of the Advocate General's opinion and the E.U.’s freedom of establishment principle.