HMRC v Fowler: More on Divers
15 Pages Posted: 24 Oct 2017 Last revised: 28 Nov 2017
Date Written: October 20, 2017
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: Suggested Citation