Market leading insight for tax experts
View online issue

P Manduca v HMRC

In P Manduca v HMRC (TC02648 – 25 April) a hedge fund manager (M) took up employment with a Luxembourg bank (D). D’s directors agreed to pay M an ‘investment bonus’ as consideration for M introducing certain business to D. However in November 2001 D made M redundant without paying him the promised ‘investment bonus’. M began legal action against D. The action was settled out of court and D agreed to pay M compensation for the loss of the ‘investment bonus’ (in addition to the redundancy payment which M had already received). In his 2002/03 return M treated the compensation payment as a capital receipt. Following an enquiry HMRC issued a closure notice treating it as chargeable to income tax (under Schedule Case VI under the legislation then in force). The FTT dismissed M’s appeal holding...

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.