Double taxation – Relief. In the deemed world introduced by s 15(2) of the Income Tax (Trading and Other Income) Act 2005, the appellant had clearly been carrying on a business, and thus 'an enterprise of a Contracting State', within the meaning of art 7(1) of the UK and South Africa Double Taxation Treaty, which was not displaced by art 14. Accordingly, the Court of Appeal, Civil Division, allowed the appellant's appeal against the decision of the Upper Tribunal (Tax and Chancery Chamber) and restored the decision that the UK was not entitled to tax his income from those activities.