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United Kingdom Upper Tribunal (Tax and Chancery Chamber)
You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> Andrew Davies and Others v Revenue and Customs (INCOME TAX - transfer of assets abroad) [2020] UKUT 67 (TCC) (10 March 2020)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2020/67.html
Cite as: [2020] STC 649, [2020] BTC 542, 22 ITL Rep 537, [2020] STI 843, [2020] UKUT 67 (TCC)
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Andrew Davies and Others v Revenue and Customs: [2020] UKUT 67 (TCC) (10 March 2020)
INCOME TAX – transfer of assets abroad – s 739 ICTA 1988, ss 720 and 721 ITA 2007 – exemption from these provisions – s 741 ICTA 1988, s 739 ITA 2007 – purposes of transactions– whether open to First-tier Tribunal to make findings, adverse to the Appellants, as to purposes – yes – whether Appellants entitled to rely on Article 7 of UK/Mauritius double tax treaty – no – whether (if they were) they were out of time to claim relief - yes.
10 March 2020
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