Smallwood and another v HM Revenue and Customs
Jurisdiction | England & Wales |
Judgment Date | 2012 |
Year | 2012 |
Date | 2012 |
Court | Special Commissioners |
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Determining corporate residence - The concept of 'place of effective management' in a shifting domestic and international fiscal landscape
- South Africa
- Business Tax and Company Law Quarterly No. 6-2, June 2015
- 1 Junio 2015
...of what happens in both jurisdictions within the context and in accordance with the terminology of the relevant DTA; 33 Ibid. 34 (2008) 10 ITLR 574 (Sp Crs); (2009) 11 ITLR 943; (2010) 12 ITLR 1002; HMRC v Smallwood [2010] EWCA Civ 778. 35 refer to the OECD Commentary on Article 4 of the MT......