Wicks v Firth (Inspector of Taxes); Johnson v Firth: CA 1981

ICI set up a trust fund to make discretionary payments to its employees to assist meeting the costs of further education. Payments made to children were treated as scholarship income and exempt under the 1970 Act. The revenue claimed it to be an employment benefit.
Held: The benefit was paid to the taxpayer’s son ‘by reason of [the taxpayer’s] employmnt within s61’. The exemption given under s375 did not exclude the charge to tax under s61.


[1982] 2 WLR 208, [1982] 2 All R 9


Income and Corporation Taxes Act 1970 375, Finance Act 1976 61

Administrative, Income Tax

Updated: 13 May 2022; Ref: scu.193467