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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 -place of effective management- 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 |