Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Fishing for FED

04 January 2011
Issue: 4286 / Categories: Tax cases
Samuel Megwa (TC796)

The appellant a mariner appealed against income assessments and amendments to his self-assessment for the years 2001/02 2002/03 and 2003/04.

HMRC rejected his claims for the foreign earnings deductions for seafarers as well as the seafarer’s earnings deduction which had replaced the former in 2003/04.

The issue involved when the taxpayer became resident and ordinarily resident in the UK. The taxpayer believed it was from May 2001 which was when he arrived in the UK to join his ship with the intention of permanently residing here.

HMRC contended that the fact appellant lived with his wife and family in Ireland until he moved to Aberdeen in February 2002 demonstrated he was not in fact resident or ordinarily resident until that time.

Although the First-tier Tribunal accepted that the taxpayer’s contention that he had always intended to make the...

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon