The government is discussing changes to the corporate tax system as a means of protecting the UK's tax revenues from being undermined by future European Court of Justice rulings.

Some drastic measures such as abolishing the ability to offset losses in one subsidiary against the profits of another are being considered as options if the government is forced to rewrite the rule book for corporate taxation. In a growing number of high-profile cases, the Luxembourg-based ECJ has decided that national tax rules are illegal under EU law.