The UK First Tier Tribunal recently issued its decision concerning the place of effective management (PoEM) at the time of a transaction involving Guernsey based trusts with two UK settlors and a Mauritius based trustee. The case involved the transfer of shares through a transaction executed by the Mauritius trustee and whether, at the time of the transaction, the PoEM should be considered Mauritius or the UK.
The two UK settlors had formed a company, Cellular Operations Limited (COL), the s…