Commentary

(d) Emolument not necessarily a reward for services

Division BII Taxation of Employment Income
| Commentary

(d) Emolument not necessarily a reward for services

| Commentary

(d)     Emolument not necessarily a reward for services

The payment need not be an actual reward for services (Hamblett v Godfrey [1986] 2 All ER 513, [1986] 1 WLR 839, 59 TC 694: lump sum one-off payment to compensate for loss of trade union rights at GCHQ taxable as an emolument from employment). Payments made by the employer for mixed reasons (both as compensation for loss of future pension rights, and to avert industrial action) were taxable as earnings; the employer's motive for making the payments was relevant. It was enough for a payment

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