Wensleydale’s Settlement Trustees v Inland Revenue Commissioners, [1996] STC (SCD) 241 at 252
Place of Effective Management
“I emphasize the adjective ‘effective’. In my opinion, it is not sufficient that some sort of management was carried on in the Republic of Ireland such as operating a bank account in the name of the trustees. ‘Effective’ implies realistic, positive management. The place of effective management is where the shots are called, to adopt a vivid transatlantic colloquialism.”
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