The test for where a trust has its tax residence is the place which is the centre of top-level management.
Mr David Shirley
[1996] STC 241
Cited by:
Cited – Revenue and Customs v Smallwood and Another CA 8-Jul-2010
The taxpayers had set up trusts which they said were based in Mauritius allowing them to claim double taxation relief. The Revenue had issued closure notices, confirmed by the SPCT, but overturned by the High Court. The Revenue appealed, saying that . .
Lists of cited by and citing cases may be incomplete.
Updated: 15 October 2021; Ref: scu.420678
