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David Richards LJ stated (at paras. 111-112): The clear conclusion to which the FTT came … was put by the FTT at [422], "the Jersey directors were acting under what they considered was an 'instruction' or 'order' from the parent". The inevitable conclusion from that finding was … that the decision to enter into the relevant transactions was taken by the parent in the UK, not by the directors in Jersey. They were, of course, concerned to ensure that what they were being instructed to do was lawful. … Likewise, the directors were concerned to ensure that there were no unexpected liabilities for the Jersey companies, such as stamp duty, and to ensure that the documents were in proper order. ...

Derrin Brothers Properties Ltd & Ors, R (on the application of) v A Judge of the First Tier Tribunal (Tax Chamber) & Ors, [2016] BTC 10, [2016] EWCA Civ 15-- summary under Article 27 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27 documentary demands made by HMRC pursuant to Art. 27 on UK companies being investigated by Australia were valid The Australian Tax Office, which suspected that a UK accounting firm was providing nominee directors and shareholders to UK-incorporated companies to make them look like they were factually resident outside Australia, made a request to the UK Revenue (HMRC) pursuant to Art. 27 of the UK-Australia Treaty (somewhat similar to Art. 24 of the Canada-U.K. ...

Derrin Brothers Properties Ltd & Ors, R (on the application of) v A Judge of the First Tier Tribunal (Tax Chamber) & Ors, [2016] BTC 10, [2016] EWCA Civ 15-- summary under Subsection 231.2(3) Summary Under Tax Topics- Income Tax Act- Section 231.2- Subsection 231.2(3) third party notices to UK accounting firm and banks did not require them to be given explanation why information required The Australian Tax Office ("ATO") made a request under Art. 27 of the UK-Australia Treaty of HMRC relating to its investigations of an Australian resident ("Gould") and his associates and clients, which suggested to it that a UK accounting firm ("Lubbock Fine") was providing nominee directors and shareholders to UK-incorporated companies to make it appear that their factual residence was outside Australia. ...