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A prima facie case of reasonable suspicion?

The extent of Comptroller of Income Tax’s (Comptroller) powers in dealing with requests from foreign tax authorities under Singapore’s exchange of information (EOI) regime was recently challenged in the High Court case of AXY and others v Comptroller of Income Tax (Attorney-General, intervener) [2017] SGHC 42. The applicant taxpayers sought leave to commence judicial review of the Comptroller’s decision to issue notices to various banks in Singapore to seek information to fulfil the requests made by the National Tax Service of the Republic of Korea (NTS) under the EOI regime.

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