F3. Gifts and voluntary payments

- Gratuity upon termination not from employment

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- Cowan v. Seymour - liquidator who gave his services gratuitously was voted a payment by the shareholders upon the completion of the liquidation as a thank you.

- Held: the sum was a gratuity/in the nature of a testimonial: "the undisputed facts show that this was not a payment for services rendered in the true sense, nor was it a profit which accrued to this gentleman by reason of his office, but it was very much more in the nature of a testimonial to him for what he had done in the past while his office, which had then terminated, was in existence." (at 380).

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Legislation: 

Cases: 

Cowan v. Seymour (1919) 7 TC 372;

HMRC manuals: 

Commentary: 

See also:

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