The Income Tax (Earnings and Pensions) Act 2003 charges to tax earnings 'from' an employment1. In asking whether earnings are from employment it is not enough that the employee would not have received the payment but for having been an employee2. The cases have established that the payment must be in return for acting as or being an employee, or as a reward for past services, as an inducement to enter into employment, or to provide future services
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