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HMRC internal manual

Employment Income Manual

Employment income: professional remuneration: practical difficulties if treated as employment income

There could be particular practical difficulties in some cases if the fees received by certain taxpayers in this type of situation were treated as employment income. For example, accountants acting as company auditors or secretaries and solicitors acting as company registrars or secretaries often hold numerous such offices concurrently as an integral part of their professional practice.

Similar difficulties can arise where a partner holds an office or employment and the fees are to be included with partnership income and pooled amongst the partners (for example, a GP with a part time NHS hospital appointment). The amount of tax payable under the rules of taxation for employment income and Trading Income will often be similar in these types of situation.