Chancery Division.

Judgment delivered 10 May 1988.

Income tax – Relief for earnings from work done abroad – Shorter or intermittent absences – Whether proportion of remuneration attributable to qualifying days to be calculated by reference to 365 days or to contractual days worked during the year – Finance Act 1977, Sch. 7, para. 2(1).

  This was an appeal by the taxpayer from the decision of a Special Commissioner that, for the purposes of relief for work done abroad, under the Finance Act 1977, Sch. 7, para. 2(1), the proportion of his salary to be attributed to one day was 1/365 of his annual salary.

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