Question of disability

The taxpayer formed NC Graphics (Cambridge) Ltd (NCG) in 1984. He sold the company 23 years later to Parametric Technology Corporation Inc (PTC).

He was retained as an employee under the terms of the sale – but his employment was terminated after a short time and he received sums that would have been payable as bonuses £83 451 compensation for loss of employment and £9 145 statutory redundancy.

A dispute arose with HMRC over the payments. The taxpayer insisted each was exempt under ITEPA 1993 s 406 because his job had been terminated as a result of his hearing difficulty. The Revenue claimed they were taxable subject to a £30 000 exemption.

The First-tier Tribunal said there was no doubt...