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HMRC internal manual

Employment Income Manual

HM Revenue & Customs
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Employment income: earnings from employment: customary payments in respect of services: example

Section 62 ITEPA 2003

Corbett v Duff (23TC763)

A professional footballer received a lump sum benefit he was permitted to receive under the Football League regulations. There was no formal agreement between the club and the player for the payment of any sum, but it was understood by all the players in the club that they were likely to get a benefit if the conditions in the regulations were satisfied. The payment was held to be taxable as earnings within Section 62. The judge said:

“The payments though not obligatory are expected, are generally asked for and are usually accorded.” (page 778)

This case demonstrates the importance of looking at all the relevant documentary evidence (in this case, the Football League regulations) and not just the contract of employment.