SE02100 - Emoluments of employees and office holders: compensation for loss of office
Sections 19 and 148 ICTA 1988
Payments of compensation for loss of office are chargeable under
Section 148 ICTA 1988, not Section 19(1)1 ICTA 1988. However, that
label can be applied to a payment when it is not appropriate: see
SE13005.
Because payments and benefits chargeable under Section 148
ICTA 1988 may qualify for exemptions (see
SE13500), it is important to recognise
the principles which determine which Section applies.
Section 148 applies where an employee receives a payment as
compensation for cancellation of a contract - as opposed to
receiving something to which contractual terms give entitlement.
The former could be:
a sum awarded as damages by a court for wrongful repudiation
of a contract, or a settlement of agreed damages without Court
involvement (see
SE13070) or
a payment made in consideration of the employee giving up all
contractual rights and ceasing to give services.
Such payments are often described as 'golden handshakes'.
They are not emoluments chargeable under Section 19(1)1 ICTA 1988
because they are not profits from the employment. They arise from
the cancellation of the service agreement. The employee loses his
right to continue to be employed and earn remuneration for his
services.
Cases in which payments for cancellation of service contracts
were held to be not chargeable under Section 19(1)1 ICTA 1988 are
DuCros v Ryall (19TC444), Duff v Barlow (23TC633) and Henley v
Murray (31TC351).
Sometimes a lump sum may be paid for more than one reason. It
will then need to be apportioned to arrive at the correct treatment
of each element: see Wales v Tilley (25TC136) and Carter v Wadman
(28TC41).
For instructions on compensation received in connection with
the termination of an office or employment the emoluments of which
have been treated as income from a trade or profession within Cases
I or II of Schedule D, see BIM40135-BIM40140.
