More TIEAs: first challenge under judicial review regime

The case of Taylor Fladgate & Yeatman Ltd v Comptroller of Taxes [2014] JRC 064 presented the Jersey Royal Court with the first application for a judicial review (JR)-based appeal against the issuance by the Comptroller of a notice to produce tax information under Regulation 3 of the Tax (Exchange of Information with Third Countries) (Jersey) Regulations 2008.

Taylor Fladgate, a Jersey incorporated company, is the majority shareholder of a Portuguese resident company, which in turn owns Quinta and Vineyard Bottlers (QVB). QVB is subject to ongoing tax litigation with the Portuguese tax administration services, which has led to an enquiry of Taylor Fladgate’s tax disbursements. Further to a request received from the Portuguese authority, the Deputy Comptroller issued a notice to Taylor Fladgate in August 2013. It sought information for the tax year 2012 concerning the legal and ultimate beneficial ownership of Taylor Fladgate, details of the periods of ownership of the above persons and any changes and income and profits.

Taylor Fladgate issued a notice of appeal on 9 September 2013, contesting whether information relating to the beneficial ownership of the company was ‘foreseeably relevant’ to the assessment and collection of taxes and alleging that it was a ‘fishing expedition’…

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