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Good shot!

09 February 2005 / Julian Hedley
Issue: 3994 / Categories: Comment & Analysis , Arctic Systems , Jones v. Garnett , Income Tax
JULIAN HEDLEY, director of Tenon Media, describes André Agassi's win in the Court of Appeal in a decision which helps to define territoriality.

SOMETHING MUST HAVE been fundamentally wrong for a high profile taxpayer like André Agassi to challenge the Inland Revenue on a point of law.

After all the UK is not his country of tax residence and why would he want to subject himself to the rigours of a civil action and the unwelcome publicity that naturally follows?

It was not a direct question of money as some might have thought but more a question of the Inland Revenue's approach to longstanding working practices. In that respect the case has similarities with Jones v Garnett otherwise known as Arctic Systems Ltd.

The appeal from the High Court to the Court of Appeal arose from a desire for clarity. The earlier decision while upholding on different grounds an earlier decision of the Special Commissioners still left many unanswered questions especially with regard to territoriality and the fact...

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