The Appellants [Mourant Trustees Limited and Carezo Limited] attempted to launch an appeal against the notices via the Royal Court. The case was heard by Lieutenant Bailiff Finch who said: “The nub of the matter, stripping aside a good deal of verbiage, is that MrPråhl does not want aspects of his affairs subjected to the unwelcome scrutiny of his native country’s tax authority.” 

The notices were submitted “to enable the STA to assess whether the Carezo and Bolero Trusts are transparent for tax purposes in Sweden and to ascertain the nature and extent of the assets, income and gains of those Trusts”. 

The argument was made that the information requested wasn’t relevant and the request was disproportionate in scope. Lieutenant Bailiff Finch refused the application to appeal, saying both grounds were unlikely to find success. 

A second judgment confirmed the first half of the Lieutenant Bailiff’s decision, but overturned the second half.  

The Appellants subsequently launched a statutory appeal on the grounds that the information in the notices was disproportionate in scope. 

There were four grounds to the appeal put forward by the Appellants. Two of the four were upheld by the Court of Appeal, but the appeal taken as a whole was dismissed. 

“Whilst nothing that we say should be seen as in any way dismissive of the need to ensure that individual rights are protected and upheld, we recall that there is also a strong public interest in the recovery of tax lawfully due and in the timely and efficient working of international agreements for the exchange of information,” the Judgment states. 

“... The validity of the Notices is therefore affirmed.”