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The cases and other authorities cited in this article relate to liability under the legislation that had effect before 2003/04, in other words, the Schedule E legislation rather than the rewritten legislation in ITEPA 2003 (see E4.101). Accordingly, since the principles described here were established, not only have the statutory provisions changed, but so has the terminology used; see E4.401. However, the overall effect of existing rules is not changed by ITEPA 2003; see E4.101. Indeed, to ensure that existing case law will apply to anything that counts as an emolument but is not listed in the definition of 'earnings' introduced by ITEPA 2003, there is a single reference to the term 'emolument' in that definition; see E4.401.

Grants and annuities paid to ministers of religion are assessable under what was Schedule E and is now ITEPA 2003 if received by virtue of the minister's office in augmentation of his stipend.

In Turner v Cuxson¹ the taxpayer, curate of Gislingham, was assessed under Schedule E (now ITEPA 2003) to include £50 received