Court of Appeal (Civil Division).

[2013] EWCA Civ 578.

Royal Courts of Justice.

Lord Justice Jackson, Lord Justice Lloyd Jones and Lord Justice Floyd.

Judgment delivered 23 May 2013.

International tax enforcement – UK–South Africa double tax convention 2002 – effect of art. 27 and 25A on enforcing past tax liabilities – whether new art. 25A has retrospective effect – OECD Model art. 27 – retrospective legislation considered – desirability of publishing memoranda of understanding – art. 31 Vienna Convention on the Law of Treaties.

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