“…rities considered by the FTT: Dreyfus v Inland Revenue Commissioners (1929) 14 TC 560, Memec Plc v Inland Revenue Commissioners [1998] STC 754 and HMRC v Anson [2015] UKSC 44, [2015] STC 1777. He said that the FTT had found that the general partner acted as trustee of the partnership assets (see FTT [135(4)], noting clause 18.4 agai…”
“…Mr Sykes next referred to Anson v Revenue and Customs Commissioners [2015] UKSC 44, [2015] 4 All ER 288, which was a case about double taxation relief. At [109] Lord Reed JSC explained that the issue in that case was whether the income on whi…”
“…ticles 31 and 32 of the Vienna Convention on the Law of Treaties; and have been amplified by such cases as IRC v Commerzbank AG [1990] STC 285 and Anson v HMRC [2015] UKSC 44, [2015] STC 1777.…”