The Bayfine Case: Elaborate Tax Avoidance Scheme Using Tax Treaty Fails in Court of Appeal of England and Wales

This article considers the UK case of Bayfine UK v. Commissioners for H M Revenue and Customs (2011) concerning an avoidance scheme, which exploited differences between the UK and US tax systems and United Kingdom-United States Income Tax Treaty (1975). In the end, the Court of Appeal decided in favour of the tax authorities.