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”).