Court of Appeal.

Fox, Stocker and Staughton L.JJ.

Judgment delivered 19 May 1989.

Income tax – Double tax relief – 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); Income and Corporation Taxes Act 1970, sec. 153, 526(5) (now Income and Corporation Taxes Act 1988, sec. 112, 832(1)).

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