Employment Income: Emoluments

15

  1. If the recipient’s contract of employment entitled him to receive the voluntary payment that is a strong ground for holding that it accrues by virtue of the office or, in other words is a remuneration for his services.
  2. The fact that the voluntary payment is of a periodic or recurrent character affords a further, though less cogent ground for the same conclusion.
  3. On the other hand, a voluntary payment may be made in circumstances which show that it is given by way of present or testimonial on grounds personal to the recipient, as, for example, a collection made for the particular individual who is at the time vicar of a given parish because he is in straitened circumstances, or a benefit held for a professional cricketer in recognition of his long and successful career in first class cricket. In such cases the proper conclusion is likely to be that the voluntary payment is not a profit accruing to the recipient by virtue of his office or employment, but a gift to him as an individual paid and received by reason of his personal needs or by reason of his personal qualities or attainments.

These principles were stated in a case which concerned a payment by a third party. At least where the payer is the employer the intentions of the payer should also be considered.71 The amount of the payment is also relevant.72

14A.4.3.3    Clergy Cases

It was decided early on that grants from a fund to supplement the incomes of clergy in poorly endowed parishes were emoluments.73 Although these grants were not from the employers they were paid for services and paid to the clergy by virtue of their offices. The reason for the payments was to augment stipends—not to make grants to clergy because they were poor. In Blakiston v Cooper74 the House of Lords held that Easter offerings which, by custom and episcopal prompting, were given to the vicar, were also taxable.75 The giving may be voluntary but it

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