HMRC wins tax treaty case against S. African diver

UK tax authority HMRC has won the right to tax the earnings of a South African resident who undertook diving work on the UK continental shelf. The case involved Martin Fowler, a South African resident, and professional diver, who undertook diving engagements in the UK Continental Shelf waters. HMRC had claimed that the income he earned while on the diving assignments would be subject to UK tax. By contrast, Fowler insisted the income should be exempt from UK income tax, as Britain and South Africa have a double-taxation treaty (also known as a double-taxation agreement, or DTA) ...