||All England Reporter
|| All ER (D) 194 (Dec)
||Upper Tribunal (Tax and Chancery Chamber)
||Iain Artis for the taxpayer.
||6 December 2010
Income tax - Assessment - Appeal - Redundancy payments - Earlier payment as compensation for variation of contractual redundancy arrangements - Subsequent redundancy - Whether earlier payment counting for purposes of exemption from and liability for income tax - s 403 - , .
Income tax Assessment. The Upper Tribunal (Tax and Chancery Chamber) found that the First Tier Tribunal had fallen into error in considering that 'termination' for the purpose of of the Income and Corporation Taxes Act 1988 meant an actual termination, and consequently that there had to be contemporaneity between the payment and the termination.
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