Triton Administration (Jersey) Limited v Comptroller of Revenue [2024] JRC 282 (10 December 2024)

The information requested is foreseeably relevant to the Swedish tax authorities' investigation of Mr Prahl's tax affairs for 2018, and thus constitutes 'tax information' under the applicable regulations. The JCA's decision to issue the notices was neither irrational nor disproportionate, and did not breach Article 8 ECHR.

Citation: [2024] JRC 282
Parties: Applicant: Triton; Respondent: Jersey Competent Authority
Jurisdiction: Jersey
Judgment Date: 10 December 2024
Procedural Posture: Judicial Review / Judgment
Outcome: Application dismissed
Legal Topics: Exchange of Tax Information, Double Taxation Agreement, Judicial Review, Foreseeable Relevance, Article 8 ECHR

Tax Law Administrative Law Human Rights Law Exchange of Tax Information Double Taxation Agreement Judicial Review Foreseeable Relevance Article 8 ECHR

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Parties

Triton

Applicant

Jersey Competent Authority

Respondent

Procedural Posture

Judicial Review / Judgment

Legal Issues

1 Whether the information requested is 'tax information' as defined under the 2008 and 2014 Regulations
2 Whether the decision to issue the notices was irrational
3 Whether the decision breached Article 8 of the European Convention on Human Rights

Ratio Decidendi

Court Disposition

Application dismissed