ÀÏ˾»úÎçÒ¹¸£Àû

Until ITEPA 2003 introduced guidelines in the form of a non-exhaustive definition (see E4.201), there had never been a statutory definition of the term 'office' and the courts struggled several times to reach a satisfactory consensus over the scope of the term. In particular they had to decide whether the word took on its ordinary dictionary meaning or whether over time it had acquired a specific meaning for tax purposes.

The definition of 'office' contained in ITEPA 2003¹ does little more than reflect the core meaning already established in judicial decisions, and the principles laid down in those decisions still hold good. No attempt is made in the statutory provisions to delineate any of the boundaries which, as the commentary that follows demonstrates, have been a perennial feature of judicial deliberations².

Until 1922 most employees were taxed under Schedule D alongside trades and professions; holders of public offices and public employments were taxed under Schedule E. The Revenue and the courts were thus faced with the difficulty of trying