The Court of Appeal restored the General Commissioners' decision upholding the taxpayers' appeal in Clark v Perks and other appeals.
In two perceptive articles in Taxation (17 February 1994, 'Seafarers: Life on the Ocean Wave' at page 421, and 16 May 1996, 'Seafarers Revisited' at page 175) Gary Axe considered, at length, the effect of 100 per cent foreign earnings deduction on seafarers in general and oil rig workers in particular. In the later article, Gary Axe gave considerable thought to what constituted a ship.