Haworth, Lenagan Kleinwort, Benson Trustees Limited v Revenue and Customs: FTTTx 2 Feb 2022

Capital Gains Tax – Application of The UK Mauritius Double Taxation Treaty to a plan to avoid capital gains tax on the sale of shares – whether the trusts which sold the shares were resident in Mauritius at the relevant time – consideration of the – place of effective management – test – on the facts, the trusts were resident in the UK – whether the operation of the treaty is excluded on the basis that the two contracting states tax different persons – no – appeals dismissed

Citations:

[2022] UKFTT 34 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Capital Gains Tax

Updated: 23 April 2022; Ref: scu.675648