United Kingdom - Fowler v. HMRC and the Murky Waters of Treaty Interpretation
- OECD,United Kingdom
- A. Jupp; J. (Joshua) Atkinson
- Bulletin for International Taxation, 2019 (Volume 73), No 6/7
- 11 June 2019
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.