The claimant sought to challenge section 58 of the 2008 Act, which imposed retrospective liability for tax, in breach of the defendant’s human rights obligations. He worked as an IT consultant through an intermediary company in the Isle of Man whose shares he owned.
Held: The claim for a judicial review on a human rights basis was dismissed.
 EWHC 97 (Admin)
England and Wales
Cited – Shiner and Another, Regina (on The Application of) v HM Revenue and Customs CA 26-May-2010
The taxpayers challenged decisions by the Revenue to apply section 858 of the 2005 Act so as to tax income earned as UK residents but as partners in an isle of Man partnership.
Held: The claim should be reconstituted as a claim for judicial . .
Lists of cited by and citing cases may be incomplete.
Income Tax, Human Rights
Updated: 13 August 2022; Ref: scu.396377