The UK companies, including Marks & Spencer Group Plc, BT Group Plc, Caterpillar Inc. and BNP Paribas SA, try to offset losses from their foreign subsidiaries under the new law that bars the companies from deducting losses made in foreign units.

Marks & Spencer, the UK largest clothing retailer, is among some other 300 UK companies that are seeking the ways to rebate money from the subsidiaries located in other countries.

The retailer has made a claim at the U.K. High Court that tax authorities discriminate between domestic and overseas units. It demands getting back some 30 million pounds ($56 million) from its loss-making Belgian, French and German units.

Wal-Mart Stores Inc., Ford Motor Co. and PepsiCo Inc., as well as many other companies, are preparing similar actions.

The law is criticised by many analysts and described as «incompatible with community law.»