Office holders are taxed in the same way as employees. There is an obvious overlap between offices and employments, and the fact that both are treated in the same way seems uncontroversial, even inevitable. Yet the current position (see E4.203) was not reached without a considerable amount of judicial heartache, and it is not possible to understand the meaning of the term 'office' for ITEPA 2003 purposes without some knowledge of its historical development (see E4.202).
Whilst, in general, ITEPA
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