Database
The immunities of States and international organisations
This database contains the original national contributions bringing together information on The immunities of States and international organisations
Information on the contribution
- Member State
- United Kingdom
- Themes
- Type of document
- Jurisprudence
- Permanent link to the contribution
- http://www.cahdidatabases.coe.int/C/Immunities/United Kingdom/1989/289
- Translations
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- No translations
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Database of the CAHDI "The immunities of States and international organisations" - contribution of United Kingdom - Jurisprudence of 03/08/1989
Database of the CAHDI "The immunities of States and international organisations" - contribution of United Kingdom - Jurisprudence of 03/08/1989
R. v. Inland Revenue Commissioners ex parte Camacq Corporation
Author(ity)
Court of Appeal
Date of the decision, of the judgment
03/08/1989
Points of law
1) Questions of the application of direct taxation to foreign sovereigns, fall outside the scope of the State Immunity Act (section 16(5));2) The Inland Revenue is entitled to refuse to pay the whole of a tax credit to a foreign sovereign, where it was clear that the transaction in question was artificially arranged to take advantage of the UK tax rules; there is no binding rule that the IR had to give consent to payment of the amount of the tax credit direct to a foreign State.
