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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