APEF v Tax Comptroller [2014] 1 JLR 100 (30 December 2013)

APEF v Tax Comptroller [2014] 1 JLR 100 (30 December 2013)

Information concerning transfer of shares apparently for no value is not 'tax information' if evidence shows transfer was for full value and registered with requesting state authorities; request for information is therefore set aside.

Citation
[2014] 1 JLR 100
Parties
Appellant: APEF; Respondent: Tax Comptroller
Jurisdiction
Jersey
Judgment Date
30 December 2013
Procedural Posture
Appeal / Judgment
Outcome
request set aside
Legal Topics
Exchange of Tax Information, Taxpayer Information Notices
Tax Law Exchange of Tax Information Taxpayer Information Notices

Case Brief

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Parties

APEF

Appellant

Tax Comptroller

Respondent

Procedural Posture

Appeal / Judgment

Legal Issues

  1. 1 Whether information concerning transfer of shares for no value constitutes 'tax information' under the Taxation (Exchange of Information with Third Countries) (Jersey) Regulations 2008
  2. 2 Whether notices requiring provision of information about taxpayer should be set aside if appellant's evidence shows request baseless

Ratio Decidendi

Information concerning transfer of shares apparently for no value is not 'tax information' if evidence shows transfer was for full value and registered with requesting state authorities; request for information is therefore set aside.

Court Disposition

request set aside

Orders

  • Notices requiring provision of information about taxpayer set aside