Alex Jupp, Joe Atkinson
Abstract
Fowler v. HMRC (2018), a case concerning a diver’s employment tax affairs, has highlighted fundamental differences of view in the interpretation of tax treaties. The article assesses the three court decisions regarding the case at the time of writing and considers what effect they may have for treaty interpretation.
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Fowler v. HMRC (2018), a case concerning a diver’s employment tax affairs, has highlighted fundamental differences of view in the interpretation of tax treaties. The article assesses the three court decisions regarding the case at the time of writing and considers what effect they may have for treaty interpretation.
Key concepts: Interpretation (philosophy), Tax treaty, Treaty, Political science, Law, Law and economics, Double taxation, Economics