The Royal Court of Jersey has dismissed the first appeal ever filed for information under a Tax Information Exchange Agreement (TIEA).
The Norwegian Tax Authority requested the information under its TIEA with Jersey after the Jersey Deputy Comptroller of Taxes issued a notice to Volaw Trust & Corporate Services in a criminal investigation. That notice required Volaw to produce documents and records concerning Berge Gerdt Larsen, a Norwegian taxpayer, and several companies. Volaw and Larsen appealed the Comptoller’s actions.
In dismissing the appeal, the Jersey court found that information obtained in a criminal investigation could be used for any of the other purposes described in the TIEA, including a civil tax assessment. The court also agreed that the Comptroller was entitled to issue the notice under the TIEA regulations.
TIEAs are bilateral agreements where the parties agree to cooperate in tax matters through the exchange of information. More than 500 TIEAs have been signed worldwide.