[2015] UKSC 44

Lord Neuberger, President, Lord Clarke, Lord Sumption, Lord Reed, Lord Carnwath

Judgment delivered 1 July 2015

Income tax – Double tax relief – Taxpayer member of Delaware limited liability company (LLC) – Taxpayer taxed in US on share of LLC profits on basis that LLC ‘transparent’ – Whether UK tax computed ‘by reference to the same profits or income’ as US tax computed – UK–US Double Tax Conventions of 1975 (art. 23) and 2001 (art. 24).

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