Royal Court upholds appeal against French Tax Information Exchange Agreement Notice

The Royal Court has, for the first time, allowed an appeal against the issuing by the Comptroller of a notice to disclose documents under the Taxation (Exchange of Information with Third Countries) (Jersey) Regulations 2008 (the TIEA regulations). The notice had been issued further to a request from the French Tax Authority (FTA) under the tax information exchange agreement (TIEA) between Jersey and France.

A Mourant Ozannes team comprising partner Justin Harvey-Hills, managing associate Mathew Cook and associate Sam Williams and Rory Mullan of Tax Chambers in London represented APEF on the expedited appeal.

The case follows the Court of Appeal’s judgment in Volaw Trust & Corporate Services Ltd & Larsen v Comptroller of Taxes [2013] JCA 239 and was heard shortly after that decision was published. Mourant Ozannes (Justin Harvey-Hills, Damian Evans and Tom Sowman) and Rory Mullan are also representing one of the appellants in that case…

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