An Update on the Availability of Relief under the US/UK Double Tax Treaty

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The UK Courts have recently passed judgment in the latest stages of two significant cases regarding the availability of relief under the US/UK Double Tax Treaty. The first case, Swift, overruled an earlier decision allowing a UK investor in a US LLC to claim relief against US tax paid on the profits of the LLC. The second, Bayfine, confirmed that the UK Courts will apply a purposive approach to interpreting the US/UK tax treaty to prevent claimants seeking to apply treaty provisions in a manner contrary to their intention. This DechertOnPoint provides further information on the recent decisions and explains possible consequences for those relying on the treaty.

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Tax

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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