The Commissioners for HM Revenue and Customs v Martin Frederick Fowler: [2017] UKUT 0219 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Smith on 30 May 2017.
Read the full decision in .
INCOME TAX – preliminary issue – section 15 ITTOIA 2005 – performance of duties of employed diver in UK waters treated as the carrying on of a trade in the UK – respondent resident in South Africa – whether income taxable as employment income under Article 14 or as business profits under Article 7 of the South Africa/UK Double Tax Treaty 2002 – interpretation of the Double Tax Treaty in accordance with the Vienna Convention on the Law of Treaties – application of Article 3(2) of the Double Tax Treaty
Updates to this page
Published 30 May 2017