GEOFFREY RICHARD HAWORTH, IAN FRANCIS LENAGAN, SG KLEINWORT HAMBROS TRUST COMPANY (UK) LIMITED v THE COMMISSIONERS FOR HIS MAJESTY鈥橲 REVENUE AND CUSTOMS [2024] UKUT 00058 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Edwin Johnson & Judge Jonathan Cannan on 04 March 2024
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Capital gains tax 鈥� treaty relief pursuant to the UK/Mauritius double taxation treaty 鈥� identifying the place of effective management of a trust for the purposes of Article 4(3) 鈥� whether the FTT applied the right test 鈥� HM Revenue and Customs v Smallwood [2010] EWCA Civ 778 applied
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Published 4 March 2024