Fowler v. HMRC and the Murky Waters of Treaty Interpretation
Journal
Country
OECD; United Kingdom
Published Date
Issue
Bulletin for International Taxation 2019 (Volume 73), No. 6/7
Document
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.