Court of Appeal.

Judgment delivered 18 February 1985.

Income tax – Reliefs – Emoluments attributable to duties performed outside 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 taxpayer against a decision of Scott J. ([1984] BTC 147), that when calculating the amount of emoluments attributable to duties performed outside the UK, an apportionment of the taxpayer’s total remuneration should be made on a time apportionment basis by reference to the amount of time he spent abroad.

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