The interest element of payments made under NHS Continuing Healthcare redress arrangements was ‘interest arising’ and the sums were ‘yearly interest’ for income tax purposes. 

Summary 

The interest element of payments made under NHS Continuing Healthcare redress arrangements was ‘interest arising’ (within ITA 2007, s 874(1)) and the sums were ‘yearly interest’ within the meaning of ITA 2007, s 874(1). 

Background 

The appellants (integrated care boards (ICBs), formerly known as CCGs) appealed against income tax assessments issued by HM Revenue and Customs (HMRC) in March 2018 and January 2019. The appeals concerned whether certain payments made by ICBs to various individuals under the NHS Continuing Healthcare (CHC) Redress arrangements were ‘interest’ for the purposes of ITA 2007, s 874 (“Duty to deduct from