The earnings of a diver within ITTOIA 2005, s 15 could not be regarded as earnings of a partnership.
The appellant, a mixed gas and air diver, was employed by two organisations (‘Technip’, and ‘Bibby’). He carried out diving work both in the UK (including the UK continental shelf) and outside the UK. In each of the relevant tax years, the appellant treated the UK employment income received from the diving companies as trading income of a partnership with his spouse.
