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2. If the amount to be paid for a period is determined before the period ends, the payment is treated as chargeable when that period ends, even though no payment has yet been made.
3. Where the amount for the period is not known until later, eg when the bonus is finalised, the date of that determination will be taken. Where more than one of these rules, including the general rules in the previous paragraph, apply, the earliest date will be taken.

14A.2.3    Ceased Office

It is not necessary that the office or employment should exist in the year in which the receipt arises.³⁹ If, in the year concerned, the office has never been held, the emoluments are to be treated as emoluments for the first year in which the office is held.⁴⁰ Conversely if the office or employment is no longer held, emoluments are to be treated as emoluments of the last such year.⁴¹ To this extent the legislation retains the doctrine of the source. ITEPA section 17 does not address the problem arising where a person holds an office, resigns it and then resumes and receives a payment between the two periods of tenure. In such circumstances the answer presumably turns on the question, ‘which period of tenure is the payment for?’.

14A.2.4    Other Rules: Non-Money Earnings and International

The timing rules for money do not override specific statutory timing rules for cash or non-cash vouchers, credit tokens and payments of compensation on retirement or removal from office.⁴² They are also excluded for the beneficial occupation rules and the rules governing benefits and expenses payment for directors and employees earning £8,500 p.a. or over (see below chapter 17). If no specific rule applies the earnings are treated as received when they are provided.

Where part 2 chapter 5 (non-UK international factors) comes into play, the legislation repeats the notions of earnings for a tax year and then repeats the rules on the timing of money earnings and non money earnings.⁴³ However the sections go on to provide the details of the remittance basis.

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