My client lives in South Africa. He is not resident in the UK and this has been the case for a number of years.
He is a self employed journalist. Much of his work is carried out for UK based news agencies or charities who contract to use his services for a short while to cover a specific issue. Other work arises via UK based agencies. All of the work however is carried on in South Africa and further afield on the continent.
For the purposes of S6 (2) ITTOIA 2005, does the fact that all of the work is carried out overseas, mean that the trade is carried on outside of the UK?