Triton Administration (Jersy) Limited v Jersey Competent Authority (Royal Court : Hearing (Civil)) [2025] JRC 041 (11 February 2025)
The information requested in the Notices is foreseeably relevant to the administration of Swedish tax law regarding Mr Prahl, and thus constitutes 'tax information' under Jersey law; the JCA's decision was not irrational or disproportionate, and the application for judicial review is dismissed.
Source-derived case information.
- Citation
- [2025] JRC 041
- Parties
- Applicant: Triton Administration (Jersey) Limited; Respondent: Jersey Competent Authority
- Jurisdiction
- Jersey
- Judgment Date
- 11 February 2025
- Procedural Posture
- Judicial Review / Final Judgment
- Outcome
- application dismissed
- Legal Topics
- Exchange of Information, Judicial Review, Tax Residence, Double Taxation Agreements, Proportionality, Article 8 ECHR
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Parties
Triton Administration (Jersey) Limited
Applicant
Jersey Competent Authority
Respondent
Procedural Posture
Judicial Review / Final Judgment
Legal Issues
- 1 Whether the information requested in the Notices constitutes 'tax information' under Jersey law
- 2 Whether the decision to issue the Notices was irrational or unreasonable
- 3 Whether the Notices are disproportionate and breach Article 8 ECHR
Ratio Decidendi
The information requested in the Notices is foreseeably relevant to the administration of Swedish tax law regarding Mr Prahl, and thus constitutes 'tax information' under Jersey law; the JCA's decision was not irrational or disproportionate, and the application for judicial review is dismissed.
Court Disposition
application dismissed
Orders
- Judicial review application dismissed; leave to pursue Article 6 ECHR ground reserved for later hearing.
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