EMI Group Electronics Ltd v Coldicott (HM Inspector of Taxes).  BTC 294
Court of Appeal (Civil Division).
Simon Brown and Chadwick LJJ and Rattee J.
Judgment delivered 16 July 1999.
Income tax – Employment – Salary in lieu of notice – Employees dismissed and paid salary in lieu of notice pursuant to contracts of employment – Whether employment was the source of payment – Whether payment ‘emoluments’ from the employment – Income and Corporation Taxes Act 1988, s. 19.
This was an appeal by EMI Group Electronics Ltd (‘the company’) from a judgment of Neuberger J ( BTC 532) that payments made to two employees in lieu of notice were taxable under Sch. E as emoluments from their employment.