Court of Session (Inner House).

Lord Justice Clerk Ross, Lord McCluskey and Lord Clyde.

Judgment delivered 29 September 1994.

Income tax – Sch. E – Emoluments from office or employment – Supplementary payment made in addition to statutory redundancy payments – Employees subsequently retained in employment by purchaser of employing company and supplementary payments made to all employees whether remaining in employment or not – Whether character of payments had changed – Whether emoluments from employment – Income and Corporation Taxes Act 1970, s. 181, 183 (1), 187(1), 188(3) (s. 19, 131(1), 148(1), 188(4) of the 1988 Act).

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