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MALCOLM GUNN FTII, TEP examines a controversial Revenue statement on termination payments.
IN 1991, THE Revenue issued a statement of practice which was part of its 'Mystifying Misinterpretations' series for practitioners. As readers may know, there is a companion set of publications, the 'Catastrophic Climbdowns' series, which is much smaller and includes the Revenue statement following the decision in Mansworth v Jelley [2003] STC 53, and another one from some years ago concerning insurance commission rebates.
MALCOLM GUNN FTII TEP examines a controversial Revenue statement on termination payments.
IN 1991 THE Revenue issued a statement of practice which was part of its 'Mystifying Misinterpretations' series for practitioners. As readers may know there is a companion set of publications the 'Catastrophic Climbdowns' series which is much smaller and includes the Revenue statement following the decision in Mansworth v Jelley [2003] STC 53 and another one from some years ago concerning insurance commission rebates.
Others in the 'Mystifying Misinterpretations' series include an early one on homes provided to beneficiaries of discretionary trusts (SP10/79) and one on company purchase of own shares from corporate shareholder (SP4/89) but the latter was transferred to the 'Staggering Successes' series following the Court of Appeal decision in Strand Options and Futures Ltd v Vojak [2004] STC 64.
The particular 1991 statement which I...
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