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First-tier Tribunal (Tax)

You are here: BAILII >> Databases >> First-tier Tribunal (Tax) >> MR GEOFFREY RICHARD HAWORTH MR IAN FRANCIS LENAGAN KLEINWORT BENSON TRUSTEES LIMITED v Revenue & Customs (CAPITAL GAINS TAX - application of the UK Mauritius double taxation treaty) [2022] UKFTT 34 (TC) (02 February 2022)
URL: http://www.bailii.org/uk/cases/UKFTT/TC/2022/TC08386.html
Cite as: [2022] STI 247, [2022] UKFTT 34 (TC)

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Decision Number:	TC 08386
Appellant:	MR GEOFFREY RICHARD HAWORTH MR IAN FRANCIS LENAGAN KLEINWORT BENSON TRUSTEES LIMITED
Respondent:	Her Majesty's Revenue & Customs
Chairmen / Special Commissioners:	Harriet MORGAN
Date Of Decision:	02/02/2022
Main Category:	PROCEDURE
Main Subcategory:	Other
Notes:	CAPITAL GAINS TAX - application of the UK/Mauritius double taxation treaty to a plan to avoid capital gains tax on the sale of shares - whether the trusts which sold the shares were resident in Mauritius at the relevant time - consideration of the -śplace of effective management-ť test - on the facts, the trusts were resident in the UK - whether the operation of the treaty is excluded on the basis that the two contracting states tax different persons - no - appeals dismissed

PDF Copy: [2022] UKFTT 34 (TC)