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Revenue and Customs and Another v Ben Nevis (Holdings) Ltd and Others: ChD 20 Jul 2012

The claimant sought to make arrangements with a view to collecting substantial arrears of tax due to South Africa. The revenue said that it had that power by virtue of the double taxation treaty with South Aftrica. The company replied that the liabilities arose for years prior to the Convention embodied in the Regulations, andtat … Continue reading Revenue and Customs and Another v Ben Nevis (Holdings) Ltd and Others: ChD 20 Jul 2012

Fowler v HM Revenue and Customs: CA 15 Nov 2018

Whether offshore diver was employee or self employed. . .

Revenue and Customs v Fowler (Income Tax): UTTC 30 May 2017

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 . .

Fowler v Revenue and Customs (Income Tax/Corporation Tax : Double Taxation): FTTTx 12 Apr 2016

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 – appellant resident in South Africa – whether income taxable as employment income under . .

Fowler v Revenue and Customs: SC 20 May 2020

The taxpayer, a diver resident in South Africa had undertaken engagements within UK waters and now disputed his liability to Income Tax using a deeming provision in section 5 of the 2005 Act being self employed.
Held: HMRC’s appeal succeeded. . .