Whether offshore diver was employee or self employed. . .

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. . .

The taxpayers challenged decisions by the Revenue to apply section 858 of the 2005 Act so as to tax income earned as UK residents but as partners in an isle of Man partnership. Held: The claim should be reconstituted as a claim for judicial review and heard together with the appeal in Huitson. [2010] EWCA … Continue reading Shiner and Another, Regina (on The Application of) v HM Revenue and Customs: CA 26 May 2010

FTTTx Income Tax – Whether payment of 300,000 euros (215,455 pounds) to settle German litigation was an expense incurred wholly and exclusively for the purposes of the trade or profession of an individual partner – Whether the payment was revenue or capital expenditure – Whether deductible under s 34 Income Tax (Trading and Other Income) … Continue reading Vaines v Revenue and Customs: FTTTx 15 Oct 2013

FTTTx INCOME TAX; provision of consultancy services; unformed company; fee for services subsequently paid to newly formed company after services performed; substance and commercial effect of arrangements; accounting treatment of fee; generally accepted accounting practice; corporation tax on fee paid by newly formed company; whether Appellant contractually or by reason of principles of unjust enrichment … Continue reading Hepburn v Revenue and Customs: FTTTx 20 Aug 2013