A payment by an employer in respect of a covenant entered into by an employee after 8 June 1988, the tenor or effect of which is to restrict his activities1 or his ability to compete with his employer, has been treated as an emolument of the employment and has therefore been taxable on the employee at both basic and higher rates. As rewritten in ITEPA 2003 with effect for 2003/04 and later years, the rules apply where a payment is made in respect of a 'restrictive
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