The Commissioners for HM Revenue and Customs v Martin Frederick Fowler: [2017] UKUT 0219 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Smith on 30 May 2017.
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INCOME TAX 鈥� preliminary issue 鈥� section 15 ITTOIA 2005 鈥� performance of duties of employed diver in UK waters treated as the carrying on of a trade in the UK 鈥� respondent resident in South Africa 鈥� whether income taxable as employment income under Article 14 or as business profits under Article 7 of the South Africa/UK Double Tax Treaty 2002 鈥� interpretation of the Double Tax Treaty in accordance with the Vienna Convention on the Law of Treaties 鈥� application of Article 3(2) of the Double Tax Treaty
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Published 30 May 2017