The Law Reports (Chancery Division)
[1973] Ch 264
[COURT OF APPEAL]
OPPENHEIMER
v.
CATTERMOLE (INSPECTOR OF TAXES)
1972 July 18,
19,
20
Lord Denning M.R., Buckley and Orr L.JJ.
Conflict of Laws
— Confiscatory or political legislation
— Nationality
— German subject emigrating to England in 1939
— German decree of 1941 depriving German Jews resident abroad of their nationality
— Naturalised British subject in 1948
— Effect of German decree
— Whether retaining German nationality for revenue purposes
Revenue
— Income tax
— Double taxation relief
— German subject emigrating to England becoming British national
— Annual pension from Germany
— Whether retaining German nationality and thereby entitled to relief against income tax
—
Double Taxation Relief (Taxes on Income) (Federal Republic of Germany) Order 1955 (S.I. 1955 No. 1203), art. IX (1)
—
Double Taxation Relief (Taxes on Income) (Federal Republic of Germany) Order 1967 (S.I. 1967 No. 25), art. IX (2)
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