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United Kingdom Upper Tribunal (Tax and Chancery Chamber)
You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> Revenue and Customs v Fowler (INCOME TAX) [2017] UKUT 219 (TCC) (30 May 2017)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2017/219.html
Cite as: [2017] STC 1385, [2017] UKUT 219 (TCC), [2017] BTC 518
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Revenue and Customs v Martin Frederick Fowler (INCOME ) [2017] UKUT 219 (TCC) (30 May 2017)
INCOME TAX – preliminary issue – section 15 ITTOIA 2005 – performance of duties of employed diver in UK waters treated as the carrying on of a trade in the UK – respondent resident in South Africa – 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 – interpretation of the Double Tax Treaty in accordance with the Vienna Convention on the Law of Treaties – application of Article 3(2) of the Double Tax Treaty
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