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Her Majesty’s Revenue & Customs (appellant) v Murphy (respondent)

Thursday 14th July 2022

This is a second appeal. By appellant’s notice filed on 15 September 2021, HMRC appeals, with the permission of Upper Tribunal Judges Mr Justice Green and Judge Greenbank, their decision of 29 June 2021, whereby they allowed the taxpayer’s appeal against the decision of the First-tier Tribunal dated 18 May 2020.

This appeal concerns the proper meaning of the term ‘profit’ as it is used in section 62(2)(b) of the Income Tax (Earnings and Pensions) Act 2003 (‘ITEPA’), which defines ‘earnings’ for the purposes of the employment income parts of the Act.

View hearing:

Part 1

Part 2