Delivery of Reserved Judgment LCCV2025/001 - Bank of Nova Scotia v The Comptroller of Inland Revenue
Автор: Caribbean Court of Justice
Загружено: 2025-11-04
Просмотров: 306
Описание: Judgment will be delivered in this appeal from Saint Lucia. The Respondent, the Comptroller of Inland Revenue (‘IRD’), levied a withholding tax of $2,142,376.80 against the Appellant, the Bank of Nova Scotia (‘BNS’). BNS disputed the imposition of the tax before the Income Tax Appeal Commissioners, but the Commissioners agreed with the IRD. BNS appealed the Commissioners’ decision to the High Court, where the learned trial judge upheld the Commissioners’ decision. BNS filed a further appeal to the Court of Appeal on seven grounds, while the IRD submitted a counter-appeal on two points. The Court of Appeal identified two key issues: (i) whether BNS was liable to pay withholding tax and (ii) whether the Commissioners were correct in interpreting ‘cost of sales’ to include interest payments. The Court of Appeal dismissed BNS’ appeal and partially allowed the counter-appeal.
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