The Smallwood Case: Dual Residence of Trustees

Journal
Cleave, B.
United Kingdom
Bulletin for International Taxation 2011 (Volume 65), No. 8
PriceUSD 45

In this article, the author considers the UK Court of Appeal decision in Trevor Smallwood and another v. Commissioners for HM Revenue and Customs (2010) regarding a tax avoidance scheme where the issue concerned the residence of trustees for the purpose of a capital gains article corresponding to article 13 of the OECD Model.