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.
Citations:
Times 16-Feb-1993
Statutes:
Income and Corporation Taxes Act 1988, Apportionment Act 1870
Jurisdiction:
England and Wales
Income Tax
Updated: 26 October 2022; Ref: scu.83027
