Chancery Division.

Judgment delivered 10 October 1986.

Income tax – Foreign earnings deduction – Qualifying days – Whether account to be taken of hours worked abroad on non-qualifying days in calculating relief – Time apportionment – Whether taxpayer’s salary should be deemed to accrue over number of working days in year or from day-to-day – Whether taxpayer entitled only to prescribed portion – Finance Act 1977, Sch. 7, para. 2 (repealed by Finance Act 1984, sec. 30(1) and Sch. 23, Pt. VII, in relation to the year 1985-86 and subsequent years of assessment).

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