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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...

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