MR GEOFFREY RICHARD HAWORTH MR IAN FRANCIS LENAGAN KLEINWORT BENSON TRUSTEES LIMITED v Revenue & Customs (CAPITAL GAINS TAX - application of the UK Mauritius double taxation treaty) [2022] UKFTT 34 (TC)
Notes: CAPITAL GAINS TAX - application of the UK/Mauritius double taxation treaty to a plan to avoid capital gains tax on the sale of shares - whether the trusts which sold the shares were resident in Mauritius at the relevant time - consideration of the -place of effective management- test - on the facts, the trusts were resident in the UK - whether the operation of the treaty is excluded on the basis that the two contracting states tax different persons - no - appeals dismissed
Cited in 1 later judgment