South African Diver Owes British Taxes, UK High Court Says

Law360 (May 20, 2020, 8:13 PM EDT) -- A South African diver must pay U.K. income tax on earnings from his work off the coast of England under a tax treaty between the two nations, the British Supreme Court ruled Wednesday. 

Earnings received by diver Martin Fowler from exploring the oil-rich North Sea should be considered to stem from employment activity, not a business trade, under British law, the court ruled. Therefore the income is taxable by the U.K. under its 2002 Double Taxation Treaty with South Africa, the court said.

Fowler was paid for diving he did on the U.K. continental shelf between 2011 and 2013. HM Revenue...

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