The Law Reports (Appeal Cases)
[1976] AC 249
[HOUSE OF LORDS]
OPPENHEIMER APPELLANT AND CATTERMOLE (INSPECTOR OF TAXES) RESPONDENT
NOTHMAN APPELLANT AND COOPER (INSPECTOR OF TAXES) RESPONDENT
1973 March 26,
27,
28,
29;
Nov 5;
Dec. 13;
1974 Nov. 6, 7, 11;
1975 Feb. 5
Nov 5;
Dec. 13;
1974 Nov. 6, 7, 11;
1975 Feb. 5
Lord Hailsham of St. Marylebone, Lord Hodson, Lord Pearson, Lord Cross of Chelsea and Lord Salmon
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
— German Basic Law of 1949 requiring Germans deprived of nationality to apply for renaturalisation
— Effect of decree and Basic Law
— Whether subject 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), Sch., art. IX (1)
[1]
—
Double Taxation Relief (Taxes on Income) (Federal Republic of Germany) Order 1967 (S.I. 1967 No. 25), Sch., art. IX (2)
[2]