The claimants sought judicial review of taxation changes which they described as the ‘extreme, unfair and unprecedented retrospective effect’ of legislation overriding all double taxation treaties so as to bring into charge to tax in the UK any share of the income of an overseas firm to which a UK resident is entitled. It was claimed that the changes caused serious concern and potential hardship to the claimants.
Held: Review refused.
References: [2011] EWCA Civ 892, [2011] STC 1878, 14 ITL Rep 113, [2011] STI 2305, [2011] BTC 444
Links: Bailii
Judges: Mummery, Sullivan, Tomlinson LJJ
Statutes: Finance Act 2008 58
Jurisdiction: England and Wales

Last Update: 12 July 2020; scu-Ref: scu.442162