New Judgment: Anson v Commissioners for Her Majesty’s Revenue and Customs  UKSC 44
01 Wednesday Jul 2015
On appeal from:  EWCA Civ 63.
The question on this appeal was whether the appellant was entitled to double taxation relief on income he remitted to the UK from the US. This depended on the interpretation of art 23(2)(a) of the UK/US Double Taxation Convention 1975 and its successor, art 24(4)(a) of the UK/US Double Taxation Convention 2001. The relevant question under both provisions is whether the UK tax is “computed by reference to the same profits or income by reference to which the United States tax is computed.”