Fowler v Commissioners for Her Majesty’s Revenue and Customs, [2020] UKSC 22

Case tabs

Summaries

Summary Under

deeming an employee to be an independent contractor did not oust the Treaty Employment Income Article

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

UK domestic provision deeming employee to be independent contractor did not engage Art. 7

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

principles in determining the scope of a deeming provision

Before going on to find that a domestic UK provision that deemed an employee to be an independent contractor for purposes of computing his income...

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