Bedell Cristin recently advised and acted for a Jersey company
(the "Company") in respect of a challenge to a notice
issued pursuant to Taxation (Exchange of Information with Third
Countries) (Jersey) Regulations 2008 (the "Regulations")
by the Comptroller of Income Tax in Jersey.
Following a change to the Regulations, enacted by the Taxation
(Exchange of Information with Third Countries) (Amendment No. 7)
(Jersey) Regulations 2013 in November last year, any challenge to
notices issued under the Regulations was required to be by way of
judicial review.
Leave was not granted in this instance, as the Comptroller was
found to have acted reasonably following the standards and
thresholds applied to his conduct in the recent Court of Appeal
decision Volaw Trust and Corporate Services Limited and Larsen
v Comptroller of Taxes ("Larsen") and the Royal Court
decision in APEF Management Company 5 Limited v Comptroller of
Taxes. However, this case presented an interesting