Special Commissioner: Dr John F Avery Jones

Decision released: 23 June 2005

Termination payment on ceasing employment – taxpayer becoming resident in the US after the payment – whether taxable in the UK – yes – whether UK taxation affected by the US-UK double taxation agreement – no


A special commissioner dismissed a taxpayer’s appeal against the refusal of his claim for exemption from UK tax under the UK–US double tax agreement in respect of a payment received on the termination of his employment with British Airways.


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