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 review and heard together with the appeal in Huitson.

[2010] EWCA Civ 558, [2010] BTC 615
Income Tax (Trading and other Income) Act 2005 858
England and Wales
CitedHuitson, Regina (on The Application of) v Revenue and Customs Admn 28-Jan-2010
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 . .

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Income Tax

Updated: 30 November 2021; Ref: scu.416106