Payments made by a Premier League football club to two players on the termination of their employment contracts with the club were not ‘from’ their respective employments.
The appellant (TH) was the parent of another company (THFAC), a Premier League football club (the companies being collectively referred to as T). In August 2011, T agreed terms with two of its players (PC and WP), which involved the players leaving T to join another club, and T making payments to the players.
HM Revenue and Customs (HMRC) considered that the payments were earnings from the players’ employments, and were subject to income tax and National Insurance contributions (NICs). HMRC issued PAYE determinations (under SI 2003/2682, reg 80) and NIC directions (under SSC(TF)A 1999, s 8). T argued that the payments were compensation for the early termination of the players’ employment contracts and, as such, were not
