Michael Phillips v HMRC  UKFTT 0174
PILON was taxable as compensation not earnings
Where there is no provision in a contract of employment for payment to be made in lieu of notice, the tax position on such payments can be unclear. In Phillips v HMRC, Mr Phillips appealed against the levy of income tax by HMRC on pay in lieu of notice made pursuant to a compromise agreement with his employer. Mr Phillips’ contract of employment made no provision for pay in lieu of notice.