Prahl and Triton Administration (Jersey) Limited v Jersey Competent Authority [2021] JRC 184 (06 July 2021)

The Applicants' case is arguable and has a realistic prospect of success on the grounds advanced, including novel points regarding tax residency and foreseeably relevant information, and therefore leave to apply for judicial review is granted.

Citation: [2021] JRC 184
Parties: First Applicant: Peder Erik Prahl; Second Applicant: Triton Administration (Jersey) Limited; Respondent: Jersey Competent Authority
Jurisdiction: Jersey
Judgment Date: 06 July 2021
Procedural Posture: Judicial Review Application (leave) / Leave to Apply for Judicial Review Granted
Outcome: Leave to apply for judicial review granted
Legal Topics: Judicial Review, Tax Information Exchange, Double Taxation, Procedural Fairness

Tax Law Administrative Law Judicial Review Tax Information Exchange Double Taxation Procedural Fairness

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Parties

Peder Erik Prahl

First Applicant

Triton Administration (Jersey) Limited

Second Applicant

Jersey Competent Authority

Respondent

Procedural Posture

Judicial Review Application (leave) / Leave to Apply for Judicial Review Granted

Legal Issues

1 Whether the Notices issued by the Respondent are defective for lack of specificity
2 Whether the information sought is 'foreseeably relevant' under the Regulations
3 Whether the Respondent acted lawfully and reasonably in issuing the Notices

Ratio Decidendi

Court Disposition

Leave to apply for judicial review granted

Orders

Leave granted to the Applicants to make an application for judicial review on all grounds sought.