Double Tax Developments: Anson v Commissioners for Her Majesty's Revenue & Customs [2015] UKSC 144

This case reached its conclusion in the English Supreme Court in July 2015. While the result was positive for Mr Anson personally, the actual remit of the case is still the subject of controversy. Following the case, Her Majesty's Revenue & Customs issued a statement that, broadly, it consi...

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Veröffentlicht in:	Business law international 2016-05, Vol.17 (2), p.161
1. Verfasser:	Wheater, Jennifer
Format:	Artikel
Sprache:	eng
Schlagworte:	Agreements Double taxation Limited liability companies Permanent establishment State laws Supreme Court decisions Tax rates Treaties
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Zusammenfassung:	This case reached its conclusion in the English Supreme Court in July 2015. While the result was positive for Mr Anson personally, the actual remit of the case is still the subject of controversy. Following the case, Her Majesty's Revenue & Customs issued a statement that, broadly, it considered Anson confined to its facts, but some have queried how this can be substantiated. In addition, the Supreme Court gave some novel reasoning in the context of previous law, and it is interesting to consider the extent to which old law still applies and new law has been created.
ISSN:	1467-632X