The taxpayer was a goalkeeper employed by Nottingham Forest Football Club. On his transfer to Southampton, he was paid pounds 75,000. The revenue appealed a finding that this was not taxable under Schedule E. Held: To be taxcable it had to be referrable to the services provided by him under the contract of employment. This … Continue reading Shilton v Wilmshurst (Inspector of Taxes): CA 1990
Retired bank employees had previously received free tax advice. When the service was withdrawn, the bank made a payment. The Revenue said that this payment was chargeable to income tax. Held: The bank’s appeal failed. The payment was made ‘in connection with’ the former employment, and viewing that in context it was a chargeable payment … Continue reading Barclays Bank Plc and Another v HM Revenue and Customs: CA 11 May 2007
The taxpayer sought tax relief for assorted pension contributions. She had made contributions to schemes before and after the 1988 Act. The tax scheme allowed unused allowances to be carried forward. The taxpayer sought to prevent aggregation of the allowances in respect of the separate schemes. Held: The unused refiefs under each scheme had to … Continue reading Lonsdale v Braisby (HMIT): ChD 23 Jul 2004
The taxpayer was transferred from one football club to another. He was paid andpound;75,000 to persuade him to move. The revenue appealed a decision that this was not a sum taxable as an emolument under Schedule E by the new employer. Held: The appeal was allowed. A payment was ‘from’ an employment if it was … Continue reading Shilton v Wilmshurst: HL 7 Feb 1991
The company director taxpayer had retired from his company but stayed on as an unpaid non-executive director. The trust deed for the company’s pension scheme provided for payments to be made to an employee. The director sought relief from payment of income tax under Schedule E. Held: (Majority) The appeal by the taxpayer was allowed. … Continue reading Venables and others v Hornby (Her Majesty’s Inspector of Taxes): HL 4 Dec 2003
The taxpayers used schemes to create allowable losses, and now appealed assessment to tax. The schemes involved a series of transactions none of which were a sham, but which had the effect of cancelling each other out. Held: If the true nature of the transactions could be seen by looking at them all together, then … Continue reading W T Ramsay Ltd v Inland Revenue Commissioners: HL 12 Mar 1981
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