Court of Appeal.

Leggatt, Morritt and Otton L JJ.

Judgment delivered 14 June 1996.

Income tax – Sch. E – Severance payment – Payment received on 6 April 1984, taxpayer having left UK on 1 April and remained abroad for whole year 1984–85 – Whether charged to tax under provisions relating to payments on retirement or removal from office or employment – Income and Corporation Taxes Act 1970, s. 181(1), 187(1) (Income and Corporation Taxes Act 1988, s. 19(1), 148).

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