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A recent decision of the Guernsey Court of Appeal brings into focus the role of HM Revenue & Customs ("HMRC") in trust proceedings before the courts of offshore financial centres and the two century old rule that foreign revenue authorities cannot seek to enforce their revenue laws outside their own borders
The Applicant applied to the Court to have an Employee Benefit Trust ("EBT") set aside and all the monies held by the trustees to be returned to the Applicant
