Identifying an occupation is a cornerstone of the sale of occupational income rules. As those rules are increasingly invoked by HMRC, Liesl Fichardt and Emily Au (Quinn Emanuel) examine the guiding principles to identify an occupation, profession and vocation, and highlight the areas of obscurity.
Are you in an ‘occupation’? This term and the terms ‘profession’ and ‘vocation’ are central to identifying chargeable income in the UK. Since Henry Addington’s Income Tax Act 1803 income tax has evolved on the basis of requiring taxpayers to contribute earnings arising from professions and vocations to the national purse (see Income Tax Act 1803 Sch D). Nevertheless those terms have never been defined in statute and although there is a vast body of case law the courts have also steered well-clear of laying down any precise definitions (see Carr v IRC [1944] 2 All ER 163 in which...
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Identifying an occupation is a cornerstone of the sale of occupational income rules. As those rules are increasingly invoked by HMRC, Liesl Fichardt and Emily Au (Quinn Emanuel) examine the guiding principles to identify an occupation, profession and vocation, and highlight the areas of obscurity.
Are you in an ‘occupation’? This term and the terms ‘profession’ and ‘vocation’ are central to identifying chargeable income in the UK. Since Henry Addington’s Income Tax Act 1803 income tax has evolved on the basis of requiring taxpayers to contribute earnings arising from professions and vocations to the national purse (see Income Tax Act 1803 Sch D). Nevertheless those terms have never been defined in statute and although there is a vast body of case law the courts have also steered well-clear of laying down any precise definitions (see Carr v IRC [1944] 2 All ER 163 in which...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
