Ex gratia termination payment was exempt from tax
SCIT Employee recognising that task for which she had been recruited was complete – over-qualified for continuing job – voluntary resignation notwithstanding loss of redundancy and other benefits of continued employment – ex-gratia payment recognising her decision – whether taxable as earnings – no – whether taxable as a termination payment – yes – whether exempt under UK/US Double Taxation Convention 2001 – yes – appeals allowed.
[2008] UKSPC SPC00710
Bailii
England and Wales
Income Tax
Updated: 01 November 2021; Ref: scu.277626