Income Tax: UK/US Treaty: relief for double taxation | Practical Law

Income Tax: UK/US Treaty: relief for double taxation | Practical Law

The Supreme Court has held that a taxpayer was entitled to the benefit of the UK/US double tax treaty in relation to profits from a Delaware LLC on the basis that the UK and US tax was computed by reference to the same profits under the treaty.

Income Tax: UK/US Treaty: relief for double taxation

Practical Law UK Articles 1-618-3093 (Approx. 3 pages)

Income Tax: UK/US Treaty: relief for double taxation

by Norton Rose Fulbright LLP
Published on 27 Aug 2015 • United Kingdom
The Supreme Court has held that a taxpayer was entitled to the benefit of the UK/US double tax treaty in relation to profits from a Delaware LLC on the basis that the UK and US tax was computed by reference to the same profits under the treaty.