Fowler v HM Revenue and Customs, [2018] EWCA Civ 2544, rev'd 2020 UKSC 22

Case History

Case tabs

Summaries

Summary Under

a domestic provision deeming employment income to be from trade rendered it business profits for Treaty purposes

The taxpayer was a resident of South Africa for purposes of the U.K-South Africa Convention (the “Treaty”) who, as an employee, undertook...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under

employment income deemed by domestic provision to be business profits

A U.K. domestic income tax provision deemed the diving activities of a South African resident in the North Sea to be the carrying on of a U.K...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under

domestic deeming provision had Treaty effect

A U.K. domestic income tax provision deemed the diving activities of a South African resident in the North Sea to be the carrying on of a U.K...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.