Chancery Division.

Sir John Vinelott.

Judgment delivered 30 October 1995.

Corporation tax – Non-resident company trading through branch or agency – Individual taxpayer resident in the UK chargeable as agent of company – Single trading transaction – Whether individual ‘regular agent’ – Taxes Management Act 1970, s. 78(1), 82.

  This was an appeal by an individual taxpayer from the decision of the general commissioners for Colchester that he was liable to corporation tax in respect of a gain realised by an Isle of Man company pursuant to the Taxes Management Act 1970, s. 78(1).

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