Chancery Division.

[The appeal against this decision is reported at [1985] BTC 150.]

Judgment delivered 4 April 1984.

Income tax – Reliefs – Emoluments attributable to duties performed abroad and in the UK – Basis of income apportionment between work abroad and in the UK – Whether time apportionment basis correct – Finance Act 1977, Sch. 7, para. 2; 4(3).

  This was an appeal by the Crown against a decision of the General Commissioners that para. 4(3) of Sch. 7 to the Finance Act 1977 provided for a larger income apportionment to be attributed to the time worked abroad by the taxpayer due to the additional burden and longer hours required.