BIM80110 - Case VI: General: casual income: contracts made in UK/abroad

Where a contract which gives rise to casual income is made in the United Kingdom, the income may be chargeable under Case VI even where the services are to be performed outside the United Kingdom (see Alloway v Phillips [1980] 53TC372). Where casual income arises from services performed in the United Kingdom and it is claimed that there is no Case VI liability because the contract was made abroad, the case should be referred to Business Tax (Technical) for advice before the absence of liability is agreed.