The court gave guidance on how an airline pilot whose earnings were in part obtained from services overseas should be taxed. The calculation should be made by calculating a ratio of earning days within the UK to those outside with a denominator of 365. Earnings for days when he was not working could not be treated as foreign earnings, and the exemption provided for this purpose should be read narrowly.
Income and Corporation Taxes Act 1988, Apportionment Act 1870
England and Wales
Updated: 09 April 2021; Ref: scu.83027