The taxpayer sought double taxation relief in respect of partnership profits earned in Jersey. Two sections appeared to be in direct contradiction. The earlier section had been superceded by the 1988 Act which was a consolidating Act. Consolidating legislation was intended to be read without reference to earlier legislation wherever possible save only in the case of ambiguity or obscure or absurd. The general rule in favour of double taxation agreements was here subordinated to a rule in 62.
Citations:
Gazette 08-Feb-2001, Times 21-Feb-2001
Statutes:
Corporation Taxes Act 1970, Income and Corporation Taxes Act 1988
Jurisdiction:
England and Wales
Taxes Management
Updated: 05 November 2022; Ref: scu.84531
