Cases
Skatteforvaltningen (the Danish Customs and Tax Administration) v Solo Capital Partners LLP & Ors, [2023] UKSC 40
The respondent, which was the Danish Customs and Tax Divisions (“SKAT”) brought claims in an English civil court seeking to recover £1.44...
United States of America v. Harden, 63 DTC 1276, [1963] CTC 450, [1963] S.C.R. 366
The U.S. government obtained a judgment from a U.S. court for U.S. income taxes owing by the respondent, who now was resident in B.C. In affirming...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Territorial Limits | revenue rule | 48 |
See Also
Skatteforvaltningen v Solo Capital Partners LLP, [2022] EWCA Civ 234, aff'd [2023] UKSC 40
The Danish Customs and Tax Divisions (“SKAT”) brought claims in an English civil court seeking to recover £1.44 billion which it had paid...
Ben Nevis (Holdings) Ltd. v. Revenue and Customs Commissioners, [2013] BTC 485, [2013] EWCA Civ 578
Before rejecting the taxpayer's submission that Article 25A did not apply to permit the collection through the respondent (HMRC) of South African...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Retroactivity/Retrospectivity | creation of new collection right did not entail retrospectivity | 182 |
| Tax Topics - Treaties - Income Tax Conventions | Vienna convention approach applies to non-signatories | 207 |
| Tax Topics - Treaties - Income Tax Conventions - Article 26A | new tax collection Article applied to old tax debts | 228 |
Relfo Ltd. v. Varsani (2008), 11 ITLR 783 (Singapore HC)
The day before going into liquidation, the directors of a company transferred all the company's assets to an overseas bank, with the equivalent...