The Chartered Institute of Taxation is calling on the government to agree to the European Commission request to implement in full the European Court of Justice judgment in Marks & Spencer on cross border loss compensation. In the legislation, meant to implement the ruling, the UK imposes conditions on cross border group relief which, says the CIOT, make it virtually impossible for taxpayers to benefit from the relief. The EC considers this is contrary to the EC treaty. The request is in the form of a 'reasoned opinion' under article 226 of the EC Treaty. If the UK does not reply satisfactorily to the reasoned opinion within two months, the commission may refer the matter to the ECJ. Ian Menzies-Conacher, chairman of the CIOT's technical committee said: 'The CIOT welcomes the European Commission's request. Taxpayers require certainty in order to operate their businesses successfully and this requires that the UK law should be properly aligned with our international tax obligations. 'We very much hope that the government will amend the law as soon as possible and without the need for further ECJ involvement. 'We consider there are other areas, such as the taxation of Controlled Foreign Companies and dividends, where the UK has not fully implemented the judgments of the ECJ.'