Update: Jersey's First Challenge Against Disclosure Under A Tax Information Exchange Agreement

[VOLAW TRUST V COMPTROLLER OF TAXES [2013]JCA239]

The Court of Appeal has dismissed the appeal and confirmed the requirement upon the appellant, Volaw Trust, to disclose the requested information to a foreign tax authority pursuant to regulation 3 of the Taxation (Exchange of Information with Third Countries) (Jersey) Regulations 2008 ("ReguIations"),.

FACTS:

In 2010, the Jersey Comptroller of Taxes ("Comptroller"), having received a request for information from foreign authorities pursuant to a Tax Information Exchange Agreement ("TIEA"), issued a formal notice to Volaw Trust requiring it, pursuant to the Regulations, to furnish "all information, documents, correspondence, financial statements, files and details of any other information concerned with or connected to the named subjects" (being an individual and four companies).