| Commentary

(a) Restrictive undertaking

| Commentary

(12)     Restrictive covenants

(a)     Restrictive undertaking

ITEPA 2003 s 225 charges to tax a payment made in respect of the giving of a restrictive undertaking by an individual in connection with that individual's current, future or past employment (ITEPA 2003 s 225(1)). A restrictive undertaking is one which restricts the individual's conduct or activities (s 225(8)). It does not matter to whom the payment is made (s 225(2)). The provision therefore charges payments made to a current, past or future employee (or to anybody else) in consideration of acceptance by that employee of

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