Queen’s Bench Division (Crown Office List).

Dyson J.

Judgment delivered 27 April 1999.

Income tax – Partnerships – UK partnerships considering becoming Jersey limited partnerships – In response to enquiry by partners the Revenue stated that UK-resident partners in a Jersey limited partnership would be taxed as if the limited partnership were a company – Whether court had jurisdiction or, if it had, would exercise discretion to make a declaration as to tax status of partners.