Corporation Tax Act 2009 section 1241

Payments in respect of employment in more than one capacity

Section 1241 deals with how redundancy or similar payments should be apportioned when an employee worked partly in the employer's investment business and partly in other capacities.

  • This section applies where an employee's role spans both the employer's investment business and one or more other capacities
  • The redundancy payment (or notional redundancy payment) must be split on a just and reasonable basis between the investment business and the other roles
  • The portion allocated to the investment business is then treated as if it related wholly to employment in that business
  • The investment business portion, once apportioned, qualifies for treatment as an expense of management under section 1240

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