- Effective place of management (Lee and Bunter v HMRC)
- Original news
- What are the practical implications of this case?
- What was this case about?
- Round-the-world schemes
- Place of effective management
- Focus of a double tax treaty is on liability to tax, not the identity of the person
- What were the facts?
- What were the issues to be decided?
- What did the FTT decide?
- Case details
Tax analysis: The First-tier Tax Tribunal (FTT) has found that the place of effective management of two settlements was the UK and as a result, capital gains tax (CGT) was payable on the gains made on the sale of shares. Although the facts of this case are not that interesting, this case provides a useful discussion on the meaning of place of effective management.
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