The term 'payment' is not confined to monetary payments. However, PAYE income which is not a payment (eg a benefit in kind) cannot be subject to deduction of tax, but may be taken into account in determining the employee's code (see E4.1132). For commentary on payrolling benefits in kind, see E4.1115.
There have been various tax cases which illustrate the wider meaning of the term 'payment' for PAYE purposes.
In Garforth1, it was held that the placing of sums unreservedly at the disposal of a director was a 'payment' within what is now ITEPA 2003, s 684.
In Paul Dunstall Organisation Ltd, Dunstall2, a company was negotiating the sale of land and arranged that part of the land should be transferred to D, a director, as a bonus; it was understood that D would then sell the land. The Special Commissioners held that the transfer of the land to D was a payment of remuneration, being money or money's worth.
In Black3, bonuses to directors of
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