Whether offshore diver was employee or self employed.
Lewison, Henderson, Baker LJJ
[2018] EWCA Civ 2544, [2019] 1 All ER 717, [2018] STI 2350, [2018] STC 2401, 21 ITL Rep 388
Bailii
Double Taxation Relief (Taxes on Income) (South Africa) Order 2002, Income Tax (Trading and Other Income) Act 2005 15
England and Wales
Citing:
At FTTTx – 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 . .
Appeal from – 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 . .
Cited by:
Appeal from CA – 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. . .
Lists of cited by and citing cases may be incomplete.
Updated: 16 October 2021; Ref: scu.630706
