[2009] UKFTT 379 (TC)

[The appeal against this decision is reported at [2011] BTC 1,562.]

Charles Hellier (Chairman)

Decision released 17 December 2009

Income tax – earnings from employment – whether payment made on TUPE transfer to recognise loss of pension scheme benefits but also to avoid industrial action was ‘from employment’ – whether capital payments could not come from employment – whether TUPE meant that for ITEPA purposes there was no change in employment – held, taxable NIC – earnings derived from employment – whether same meaning as ‘from employment’

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