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Deemed trading income constitutes business profits under double tax treaty (Fowler v HMRC)

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Published on: 15 April 2016
Published by a LexisNexis Tax expert

Table of contents

  • Original news
  • What was this case about?
  • What did the FTT decide?
  • What should tax lawyers take note of?

Article summary

Tax analysis: The First-tier Tax Tribunal (FTT) found that employment income that is deemed to be trading income under UK tax rules, should be treated as business profits for the purposes of the double tax treaty (DTT) between the UK and South Africa.

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Jurisdiction(s):
United Kingdom

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