In the looking glass: holding companies and reflective loss

Abstract

The purpose of this article is to examine, in the light of the very recent Guernsey judgment of Her Honour Lt Bailiff Hazell Marshall QC in Jefcoate v Spread Trustee,¹ the so-called rule against the recovery of ‘reflective loss’ so far as it applies to claims for breach of trust by beneficiaries against their trustee, where the loss has been suffered by a company directly or indirectly owned by the trust.