Puttnam v Revenue & Customs (INCOME TAX/CORPORATION TAX : Other) [2019] UKFTT 389 (TC) (17 June 2019)
Section 15 ITTOIA 2005 does not permit employment income of a diver to be treated as trading income of a partnership; it only deems the individual diver to be carrying on a trade for income tax purposes. The appellant was an employee of Subsea 7, not self-employed, and the income was not that of a partnership.
Source-derived case information.
- Citation
- [2019] UKFTT 389
- Parties
- Appellant: Jospeh Puttnam; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
- Jurisdiction
- United Kingdom
- Judgment Date
- 17 June 2019
- Procedural Posture
- Income Tax/corporation Tax Appeal / First Tier Tribunal (tax Chamber) Decision
- Outcome
- Appeal dismissed
- Legal Topics
- Income Tax, Employment Status, Partnership Law, Statutory Interpretation
Source-derived case record
Summary, issues, holding and outcome
More case intelligence is available
Unlock the full research layer for this judgment.
Parties
Jospeh Puttnam
Appellant
The Commissioners for Her Majesty’s Revenue & Customs
Respondents
Procedural Posture
Income Tax/corporation Tax Appeal / First Tier Tribunal (tax Chamber) Decision
Legal Issues
- 1 Whether earnings of a diver within s15 ITTOIA 2005 can be regarded as earnings of a partnership
- 2 Whether the diver was self-employed or an employee
Ratio Decidendi
Section 15 ITTOIA 2005 does not permit employment income of a diver to be treated as trading income of a partnership; it only deems the individual diver to be carrying on a trade for income tax purposes. The appellant was an employee of Subsea 7, not self-employed, and the income was not that of a partnership.
Court Disposition
Appeal dismissed
Full Case Text
Judgment text and source record
Sign in to read
Sign in to read the full judgment text
Sign in to read the full judgment text. Downloads and additional research tools may depend on your plan.
Sign in to read the full judgment