HMRC plan to withdraw three extra-statutory concessions (ESCs):

• 
  Employment Income Manual 03002, “Professional remuneration (income tax)”
• 
  Sports testimonials (income tax)
• 
  D45, “Capital gains tax: roll-over into depreciating assets”

The first enables an individual to treat employment income as trading income chargeable to income tax (for a sole trader/partnership) or corporation tax by relieving the company or organisation paying the remuneration of the obligation to operate PAYE in respect of relevant payments of employment income.

The Revenue believes the Department for Environment Food and Rural Affairs (Defra) was the main user of the practice until it amended its own legislation from April 2014 on the …