Eaton-Turner v McKenna (HM Inspector of Taxes)     Income Tax – Resident in the United Kingdom – Earnings arising wholly from employment
abroad – Whether earnings chargeable to income tax – Income Tax Act 1918 (c 40), s 1,
sched D, case II, sched E, r 6 – Finance Act 1922 (c 17), s 18.
The appellant, who at all relevant times was a person residing in the United Kingdom for the
purposes of the Income Tax Acts, was employed by an English company at the company’s
mines in West Africa, and the whole of his duties were performed outside the United
Kingdom. The greater part of his remuneration was paid in London, and the remainder was
paid abroad. The appellant, having been assessed to income tax under sched E of the Income
Tax Act 1918, as amended by the Finance Act 1922, s 18, in respect of the remuneration
arising from his employment, contended that under the Acts there was no liability for income
tax upon the profits of an employment carried on wholly outside the United Kingdom, and
that his employment was not an employment of profit in the United Kingdom for any of the
years of assessment within the meaning of sched E, r 6, which provides that “the tax shall be
paid in respect of all the public offices and employments of profit within the United
Kingdom. … ”