J Gordon Reid QC, F.C.I.Arb

Decision released 8 November 2007

Social Security Contributions (Transfer of Functions etc.) Act 1999 s. 8, ICTA 1988, s. 313 – Non-compete agreement; liability to pay secondary contributions – Share purchase agreement – Service agreement– Whether sum paid as consideration in non compete-agreement fell within s. 313– Yes– Appeal dismissed


A special commissioner decided that payments made in return for undertakings in a non-compete agreement fell within ICTA 1988, s. 313, which brought into charge to tax under Sch. E payments made before, during or after employment.


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