The seafarer’s earnings deduction is allowed for an amount equal to the earnings attributable to the eligible period (ITEPA 2003, s. 379). As the legislation applies to all earnings attributable to the eligible period, ‘is not necessary to separate out or apportion earnings arising from the United Kingdom and from abroad’ (EIM 33002).

The Explanatory Notes to the Income Tax (Earnings and Pensions) Act 2003 stated (at para. 1659) that ‘this deduction has something of the flavour of an exemption in that the amount deductible is equal to an amount of earnings rather than any costs or expenses incurred’.

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