GEOFFREY RICHARD HAWORTH, IAN FRANCIS LENAGAN, SG KLEINWORT HAMBROS TRUST COMPANY (UK) LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2024] UKUT 00058 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Edwin Johnson & Judge Jonathan Cannan on 04 March 2024
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Capital gains tax – treaty relief pursuant to the UK/Mauritius double taxation treaty – identifying the place of effective management of a trust for the purposes of Article 4(3) – whether the FTT applied the right test – HM Revenue and Customs v Smallwood [2010] EWCA Civ 778 applied