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On appeal from: [2013] 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.”

For judgment, please download: [2014] UKSC 44
For Court’s press summary, please download: Court’s Press Release
For a non-PDF version of the judgment, please visit: BAILII

To watch hearing, please visit: Morning session (27 Oct 2014), Afternoon session (27 Oct 2014), Morning Session (28 Oct 2014)