Triton Administration (Jersey) Limited v Comptroller of Revenue [2024] JRC 283 (10 December 2024)

Triton Administration (Jersey) Limited v Comptroller of Revenue [2024] JRC 283 (10 December 2024)

The remote possibility of appeal or Article 6 infringement is outweighed by Jersey's obligation under the Convention on Mutual Assistance and the public interest in timely compliance; therefore, early release of information is justified.

Source-derived case information.

Citation
[2024] JRC 283
Parties
Applicant: Jersey Competent Authority; Respondent: Triton; Third Party: Swedish Tax Authority
Jurisdiction
Jersey
Judgment Date
10 December 2024
Procedural Posture
Judicial Review / Post Judgment, Application for Early Release of Information
Outcome
application granted
Legal Topics
Judicial Review, Release of Information, Convention on Mutual Assistance, Article 6 ECHR
Administrative Law International Cooperation Judicial Review Release of Information Convention on Mutual Assistance Article 6 ECHR

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Parties

Jersey Competent Authority

Applicant

Triton

Respondent

Swedish Tax Authority

Third Party

Procedural Posture

Judicial Review / Post Judgment, Application for Early Release of Information

Legal Issues

  1. 1 Should the Jersey Competent Authority be permitted to release information to Sweden before the conclusion of judicial review proceedings?
  2. 2 Does early release of information infringe Article 6 ECHR rights of Triton?
  3. 3 Does the right to appeal to the JCPC or CA require suspension of release?

Ratio Decidendi

The remote possibility of appeal or Article 6 infringement is outweighed by Jersey's obligation under the Convention on Mutual Assistance and the public interest in timely compliance; therefore, early release of information is justified.

Court Disposition

application granted

Orders

  • Order permitting release of information under Regulation 14(3)(b)(iii) to Swedish Tax Authority.
  • Order suspended until midday on Friday 13 December 2024 to allow for urgent application to Court of Appeal.