- When is information ‘foreseeably relevant’ to overseas tax authorities? (Berlioz Investment Fund SA v Directeur de l’administration des contributions directes)
- Original news
- What was the background to this case?
- What did the Court of Justice decide?
- Does this case expand the grounds on which a person can challenge an information notice issued by HMRC following a request for information exchange from another country?
- Would the consequences be similar under the various non-EU conventions on exchange of information (such as double tax treaties or the Convention on Mutual Administrative Assistance in Tax Matters)?
Tax analysis: The Court of Justice found that the ‘foreseeable relevance’ test must be satisfied in order for a request for information from an overseas tax authority to be legally upheld. David Klass, partner in Gide Loyrette Nouel LLP’s London tax practice, considers the wider implications of Berlioz Investment Fund SA v Directeur de l’administration des contributions directes.
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