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E Fountain v HMRC

In E Fountain v HMRC (TC01413 – 12 October) an individual (F) was employed under a contract which stipulated that he would be paid monthly in arrears on the 6th of each month.

HMRC issued a ruling that the payment which he received on 6 April 2007 was taxable for 2007/08. F appealed contending that it was taxable in 2006/07.

The First-tier Tribunal rejected this contention and dismissed the appeal. Judge King held that the effect of ITEPA 2003 s 18(1) was that the payment was taxable when F became entitled to it which was on 6 April 2007.

Why it matters: In both Heasman v Jordan (35 TC 518) and Griffin v Standish (1995 STC 825) the Ch D held that payments of earned income were taxable for the period in which they were earned although...

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