HMRC v Fowler: More on Divers

15 Pages Posted: 24 Oct 2017 Last revised: 28 Nov 2017

See all articles by John Avery Jones

John Avery Jones

London School of Economics & Political Science (LSE) - London School of Economics

Date Written: October 20, 2017

Abstract

Case note on the Upper Tribunal decision in Fowler v HMRC. See http://ssrn.com/abstract=3006295 for a note (jointly with Johnann Hattingh) on the First-tier Tribunal decision.

Note: “This material was first published by Sweet & Maxwell Limited in John F. Avery Jones, HMRC v Fowler: more on divers, Issue 4 2017 of the British Tax Review and is reproduced by agreement with the Publishers.”

Keywords: Divers, Double taxation treaties, Employment income, Income tax, Trading income, South Africa, Treaty interpretation

JEL Classification: K34

Suggested Citation

Avery Jones, John, HMRC v Fowler: More on Divers (October 20, 2017). Available at SSRN: https://ssrn.com/abstract=3056362 or http://dx.doi.org/10.2139/ssrn.3056362

John Avery Jones (Contact Author)

London School of Economics & Political Science (LSE) - London School of Economics ( email )

United Kingdom

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