Nov 2013
##BERMUDA
###COURT OF APPEAL
####CIVIL APPEAL – TAX INFORMATION EXCHANGE AGREEMENTS – DISCLOSURE OF BASIS FOR REQUEST – STATUTORY NOTICE TO DELIVER UP INFORMATION
This appeal was against the judgment of Hellman J dated 13 March 2013 which granted an application for judicial review made by Bunge Limited (“Bunge”) in relation to a statutory demand for information made by the Minister of Finance, the Appellant, under the _International Cooperation (Tax Information Exchange Agreements) Act, 2005_ (the “2005 Act”). The 2005 Act “_makes general provision for the implementation of tax information exchange agreements entered into by the Government of Bermuda… with other jurisdictions_”. The relevant Agreement was made between the Governments of Bermuda and Argentina and came into force on 14 October 2011 (“the Agreement”).