Payments to directors who had resigned voluntarily were taxable earnings and were not exempt payments of compensation for loss of office.  

The appellant companies (S and A) were connected with a limited liability partnership (R). The directors were all limited partners in R. S was a limited partner in R between January 2013 and March 2015. A (incorporated in 2006) was also briefly a limited partner in R. In 2010, when R was formed, a further company (S8) was formed as a holding company. A was owned by S8, and S8 was owned by R. R’s business was the promotion of tax arrangements; the appellants participated in them.  

The appellants appealed against notices of determination under SI 2003/2683, reg 80 and notices under SSC(TF)A 1999, s 8 in respect of tax years from 2015/16 to 2018/19. The determinations and section 8 notices related to payments made to five directors of S and A on the termination of their respective