The company owed very substantial arrears of tax in South Africa. Assets had been transferred to a bank account in London in the name of an associated company. The double taxation treaty with South Africa now provided for mutlual assistance and the Revenue had sought access to the account for this purpose. The company appealed.
Jackson, Lloyd Jones, Dloyd LJJ
[2013] EWCA Civ 578
Bailii
England and Wales
Citing:
Cited – Inland Revenue Commissioners v Commerzbank AG ChD 1990
Mummery J set out the correct approach to interpretation of double taxation agreements as laid down in Fothergill. He said ‘(1) It is necessary to look first for a clear meaning of the words used in the relevant article of the convention, bearing in . .
Appeal from – Revenue and Customs and Another v Ben Nevis (Holdings) Ltd and Others ChD 20-Jul-2012
The claimant sought to make arrangements with a view to collecting substantial arrears of tax due to South Africa. The revenue said that it had that power by virtue of the double taxation treaty with South Aftrica. The company replied that the . .
Lists of cited by and citing cases may be incomplete.
Updated: 30 October 2021; Ref: scu.510025