BIM14065 - Schedule D: Receipts not chargeable: Source doctrine

Receipts, to be chargeable to Income Tax, must arise from a source. To put the point another way, they must fall within the words of the charging provisions. If, for example, a taxpayer is a trader that does not mean that any non-capital receipt he or she gets is chargeable under Case I. It must also be an annual profit or gain from the trade, which is the taxable 'source'.

Assume, for example, that a greengrocer witnesses a car breakdown outside the business premises. The greengrocer takes the passengers to their destination, repairs the car and delivers it to its owner. Later he or she receives an unsought payment from the motorist in appreciation of the assistance provided. That amount is not from the greengrocer's trade. It is not liable under Case I as part of the receipts of that trade. The payment, because it is unsolicited and made in recognition of the recipient's personal qualities, is unlikely to be from any source and is almost certainly outside income taxation altogether.

Casual or occasional payments may, in some circumstances, be liable under Schedule D Case VI. There is guidance at BIM80100 onwards.