Ch D 1990, 63 TC 729; [1991] STC 42
O’Leary was a professional footballer, who was resident and ordinarily resident but not domiciled in the UK. His employer set up an offshore trust for him and made a sizeable loan to the trust. The interest earned was paid to O’Leary under the terms of the settlement. The taxpayer claimed that the interest was foreign investment income and therefore assessable on the remittance basis; the Inland Revenue contended that the income was earnings from employment and taxable on the arising basis.
It was held that the income was derived from the player’s employment and therefore taxable on the arising basis.
