Chancery Division.

[The appeal against this decision is reported at [1989] BTC 221.]

Judgment delivered 1 December 1986.

Income tax – Double tax relief – Sch. D, Case V – Whether income of a UK resident partner in a Jersey partnership from the partnership trade was exempt from UK tax as the industrial or commercial profits of a Jersey enterprise – Whether Jersey partnership was a body of persons resident in Jersey for purposes of Jersey tax – Double Taxation Relief (Taxes on Income) (Jersey) Order 1952 (S.I. 1952 No. 1216).

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