McCann: analysing the Anson Supreme Court ruling

The Supreme Court ruling in Anson [Anson v Commissioners for Her Majesty’s Revenue and Customs, [2015] UKSC 44; on appeal from [2013] EWCA Civ 63] is arguably the most significant double tax treaty case in years. Ray McCann considers the impact on US LLC members based in the UK for tax purposes

Double tax treaties are hugely important in ensuring that so far as possible taxpayers who have tax positions in two or more different jurisdictions pay tax once only on the same income or that overall, where two states have the right to tax the income, the tax paid on that income is no more than would be paid if the income was taxed only once.

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