Redundancy + termination → Injury + disability exemption (s.406)
Injury + Disability Termination Exemption — ITEPA 2003 s.406 (No £30k Cap)
ITEPA 2003 s.406 provides a full income tax exemption — with no £30,000 cap — for termination payments and benefits received on account of injury to, or disability of, an employee. Unlike the s.401 / £30k cap, s.406 is unlimited. But HMRC scrutinises it heavily: the exemption requires (a) a genuine injury or disability of the employee; (b) a real connection between that condition and the termination; and (c) contemporaneous medical evidence. 'Stress' on its own usually does not qualify unless it amounts to a recognised psychiatric illness with documented diagnosis and a clear causal link to the termination. The cold-pitch market 'stress-claim conversion specialist £2k+' is largely fraudulent — characterisation is a fact-and-evidence question, not a structuring choice.
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In plain English
s.406 ITEPA gives a much broader exemption than the £30,000 cap — payments received because of a genuine workplace injury or a disability that ended your employment are fully exempt from income tax, with no upper limit. Examples that clearly qualify: • A construction worker who suffers a serious back injury at work and accepts a payment to leave because they can no longer perform the role. • An office worker diagnosed with a long-term disability that materially affects their ability to do the job, who accepts ill-health retirement compensation. • An employee with diagnosed PTSD or major depressive disorder (with consultant psychiatrist evidence) who leaves under a settlement that genuinely compensates for the impact of the workplace condition. What does NOT qualify just by labelling: • 'Stress' without a recognised diagnosis — HMRC's position is that ordinary work-related stress is not a disability for s.406 purposes. • A settlement of an ordinary redundancy with a 'stress' line added to absorb the slice above £30k — this is the pattern HMRC enquires hardest on. • An injury that occurred years before termination and was unrelated to the leaving event. Documentation is everything: GP or consultant letters; occupational health reports; sickness absence records contemporaneous with the condition; medical opinion confirming the causal link between condition and termination.
How it works
The three-element test
For s.406 to apply: (1) the employee has an injury or disability; (2) the payment / benefit is received on account of that injury or disability; (3) there is a genuine causal link between the condition and the termination. HMRC will look at medical records, occupational health reports, sickness absence patterns, and the settlement-agreement drafting to assess each element.
What 'disability' means
Generally aligned with the Equality Act 2010 concept — a physical or mental impairment with substantial and long-term adverse effect on ability to carry out normal day-to-day activities. Specifically includes recognised psychiatric conditions diagnosed by a qualified clinician.
Stress as a borderline category
Generic 'work stress' without a clinical diagnosis is typically NOT a disability for s.406 purposes. Where stress has progressed to recognised conditions — clinical depression, generalised anxiety disorder, PTSD — with consultant evidence and a clear connection to the workplace, s.406 may apply. HMRC's enquiry rate on stress-characterised s.406 use is high.
Documentation requirements
Best practice: contemporaneous medical evidence (GP letters, consultant reports, OH assessments) predating the settlement; a specific recital in the settlement agreement identifying the s.406 amount and the underlying condition; an option for the employer to make the s.406 payment conditional on receipt of an independent medical opinion confirming the connection.
Mixed settlements
A settlement can have a s.406 slice and a s.401 slice. Example: a £100k package might be split £40k under s.406 (injury / disability compensation, fully exempt with medical evidence) + £30k under s.401 (ordinary ex-gratia, within £30k cap) + £30k taxable balance. Split-line drafting is essential.
Who this applies to + key conditions
- Employee has a genuine injury or disability (recognised condition with medical evidence)
- Payment / benefit is received on account of that condition
- Genuine causal link between condition and termination
- Contemporaneous medical documentation available
- Settlement agreement explicitly identifies the s.406 amount and basis
Statute + manual references
Primary: ITEPA 2003 section 406 — exemption from income tax for payments and benefits received on account of injury or disability.
Related: ITEPA 2003 s.401-416 — surrounding termination payment regime; Equality Act 2010 — definition of disability (long-term physical or mental impairment with substantial adverse effect)
HMRC manual: EIM13610 onwards — injury / disability exemption; EIM13615 (disability evidence); EIM13620 (psychological injury)
Common mistakes + traps
- Using s.406 as a generic top-up above £30k without medical evidence — high HMRC enquiry risk
- Labelling ordinary work stress as 'disability' without clinical diagnosis
- Missing contemporaneous medical evidence — only obtaining a letter at settlement time looks self-serving
- Failing to recite the s.406 basis in the agreement — HMRC has no clear documentary hook
- Bundling s.406 and s.401 in a single 'compensation' line — needs split-line drafting
Worked example
Lena, age 52, customer-service team leader, diagnosed with severe clinical depression after 18 months of escalating workplace bullying; clinical psychiatrist diagnosis Sept 2024; 9 months sickness absence; settled exit February 2026
Settlement: £25,000 ex-gratia compensation for loss of office (within s.401); £35,000 in connection with Lena's diagnosed condition under s.406; £4,000 holiday pay; total £64,000.
- Step 1 — Documentation: Lena's psychiatrist's diagnosis letter (Sept 2024); GP records of sickness absence (June 2024 onwards); occupational health report (Nov 2024); ACAS-conciliated grievance correspondence (Jan-Feb 2026) referencing health impact.
- Step 2 — Settlement-agreement drafting: separate recital identifies the £35,000 as 'in respect of the Employee's diagnosed condition referred to in the medical reports listed at Schedule 2, in connection with the termination of employment'.
- Step 3 — Tax: £4,000 holiday pay — PAYE + NIC. £25,000 ex-gratia — within s.401 / £30k cap, tax-free. £35,000 under s.406 — full exemption, tax-free, no NIC.
- Step 4 — HMRC enquiry risk: documentation supports the s.406 characterisation. If HMRC challenges, Lena's medical evidence pack is contemporaneous and clearly causal.
Outcome: Lena receives £60,000 tax-free + £4,000 holiday taxed normally. Defensible against HMRC enquiry because of contemporaneous medical evidence and explicit settlement recital.
How this connects to the rest of the framework
s.406 sits outside the £30k cap entirely — and can be combined with s.401 slices in the same settlement.
Mixed s.406 + s.401 settlements need explicit line-item drafting.
Stress-related termination scenario shows medical-evidence threshold in practice.
Frequently asked questions
What happens if I miss the Self Assessment deadline?+
Do I need an accountant or can I file Self Assessment myself?+
How do payments on account work?+
Can I use s.406 retroactively for an old injury?+
Does s.406 apply to dependants' payments after death in service?+
Is workplace stress alone enough?+
Does s.406 attract NIC?+
Free + regulated-body resources
- HMRC EIM13610 — injury / disability exemption →
Authority on s.406 mechanics
- HMRC EIM13620 — psychological injury →
Practice on stress / psychiatric conditions
- ACAS — disability and work →
Free guidance on the workplace dimension
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