Mr Theodore Wallace.

Decision released 14 December 1995.

Income tax – Emoluments of employment – Agreements between directors and non-resident company associated with employer to pay sum in return for directors continuing in employment until takeover – Whether emoluments – If so, whether emoluments consisted in contractual rights or the payments – Payments were emoluments of employment – Appeal dismissed – Income and Corporation Taxes Act 1970, s. 181(1) (Income and Corporation Taxes Act 1988, s. 19(1)).

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