In I Cameron v HMRC (and related application) (QB – 8 May) HMRC rejected two claims for seafarers’ earnings deduction. The claimants appealed contending that an HMRC publication entitled Seafarers – Notes on Claims for 100% Foreign Earnings Deductions which had originally been published in 1993 and was colloquially known as ‘the Blue Book’ had given them a legitimate expectation that they would be entitled to the relief. The QB accepted this contention and allowed their applications. Wyn Williams J observed that both the ‘Blue Book’ and form S203(New) stated that a day would be treated as a day of absence from the UK if the claimant was outside the UK at the end of that day (ie even if he had only left the UK in the late evening). However HMRC had subsequently formed the opinion that the...
