| Commentary

(b) Second-hand value

| Commentary

(b)     Second-hand value

The basic rule (under Part 3 Ch 1, the charge on 'earnings') is that where an individual receives a benefit from his employment, he is taxable on the realisable value of the benefit as an emolument, namely the extent to which (if at all) the benefit can be turned into money. This is sometimes called the 'money's worth' or 'second hand value' principle (see Tennant v Smith [1892] AC 150, 3 TC 158, HL; Wilkins v Rogerson [1961] Ch 133, 39 TC 344, CA). It also applies (see

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