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PILONs Paid on Redundancy

 
Nigel Doran partner in the corporate tax group at Macfarlanes considers the decision in SCA Packaging Ltd on the taxation of PILONs paid on redundancy
 
The decision of the Special Commissioners in SCA Packaging Ltd v HMRC SpC 541 is an interesting and important decision on the common situation in which an employer embarks on a redundancy programme and asks the affected employees to work for part only of their notice period and to receive a payment in lieu of notice in respect of the remaining part.
 
The facts of the case are extremely complex covering a number of employees engaged under different employment contracts affected by different agreements with trade unions and working in different parts of the UK. This explains why the Special Commissioner's decision...

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