Redundancy + termination → Restrictive covenants
Restrictive Covenants on Termination — Hasted v Horner (1995) 67 TC 439
Payments made in consideration of restrictive covenants — non-compete, non-solicit, non-deal, confidentiality clauses backed by consideration — are fully taxable as ordinary employment income and CANNOT fall within the £30,000 s.401 exemption. HMRC's authority is in EIM12977+ and EIM13630; the leading case is Hasted v Horner (1995) 67 TC 439 (Vinelott J, ChD). The practical risk in settlement-agreement drafting is that ambiguous or broadly drafted restrictive covenant consideration can re-characterise what 'feels' ex-gratia into the fully-taxable bucket. Best practice: allocate restrictive covenant consideration on its own clearly-identified line and tax it in full, so the remaining compensation for loss of office is unambiguously within s.401.
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In plain English
Restrictive covenants are post-termination contractual obligations: don't compete with the employer, don't poach clients, don't poach staff, keep confidential information confidential. Where the leaver receives a payment specifically in consideration of accepting or reaffirming such covenants, that payment is treated as ordinary employment income and taxed in full — even though the leaver is no longer working for the employer. The leading authority is Hasted v Horner (1995) 67 TC 439, decided by Vinelott J in the Chancery Division. The case established that restrictive covenant consideration cannot benefit from termination-payment treatment. The current statutory hook is ITEPA 2003 s.225 (consideration for restrictive undertakings), reflected in HMRC's Employment Income Manual at EIM12977 onwards and EIM13630. The practical trap in settlement-agreement drafting: if the agreement says 'in consideration of the covenants set out in clause X and the release of all claims, the Employer shall pay £30,000', HMRC may argue that some or all of that £30,000 is restrictive covenant consideration — fully taxable, no £30k exemption. The fix is to split the consideration explicitly: 'In consideration of the covenants in clause X, £1,000 (taxable in full). In compensation for loss of office, £29,000 (within ITEPA s.401).' The £1,000 absorbs the restrictive covenant tax; the £29,000 sits cleanly within the £30k exemption. This is one area where a qualified employment lawyer + an accountant earn their fees — not the £1,500 'specialist' tier.
How it works
Why the £30k exemption doesn't apply
ITEPA s.401 covers payments 'received in connection with the termination of employment'. Restrictive covenant payments are received in connection with FUTURE obligations of the leaver, not in connection with the termination itself. Hasted v Horner confirmed this characterisation — and the practical effect is that s.225 ITEPA charges them in full.
The drafting fix
Split the consideration explicitly in the settlement: a clear, separate line item for restrictive covenant consideration (taxed in full at the time of payment via PAYE); a clear, separate line item for compensation for loss of office (within s.401 / £30k). HMRC will respect a properly-drafted split.
Reasonableness + nominal consideration
There is no rule that restrictive covenant consideration must be 'substantial' to be valid as a tax matter — £1 will do for tax characterisation purposes, although under contract law a more substantial consideration may be required for enforceability of broad covenants. Practitioners often allocate £500-£1,000 to restrictive covenants and route the rest as ex-gratia.
Confidentiality clauses
Ordinary confidentiality clauses (continuing the existing duty of confidentiality) do not, by themselves, require separate consideration. But where the agreement explicitly pays for confidentiality (e.g. an NDA premium), HMRC may characterise that consideration as restrictive covenant payment — fully taxable.
Class 1 NIC + employer NIC
Restrictive covenant payments attract full Class 1 employee NIC and employer NIC, in addition to PAYE income tax. This is in contrast to s.401 payments, where the £30k+ slice attracts only employer Class 1A NIC from April 2020.
Who this applies to + key conditions
- Any UK employment termination where consideration is paid for accepting / reaffirming post-termination restrictions
- Applies whether covenants are non-compete, non-solicit, non-deal, or confidentiality-backed by consideration
- Applies regardless of whether the covenants were originally in the employment contract or newly imposed at settlement
Statute + manual references
Primary: ITEPA 2003 s.225 — consideration for restrictive undertakings is chargeable as employment income.
Related: ITEPA 2003 s.401-416 — termination payment regime that does NOT apply to restrictive covenant payments; ITEPA 2003 s.6 — general charge on employment income
HMRC manual: EIM12977+ (restrictive undertakings); EIM13630 (interaction with termination payments + Hasted v Horner)
Case law: Hasted v Horner (1995) 67 TC 439 (Vinelott J, ChD) — restrictive covenant payment characterisation; leading authority
Common mistakes + traps
- Treating restrictive covenant consideration as £30k-exempt — Hasted v Horner forecloses this
- Bundling consideration in a single 'compensation' line — HMRC re-characterises and taxes adversely
- Forgetting employer + employee NIC apply (s.401 only attracts employer Class 1A above £30k)
- Allocating £0 explicit consideration when broad covenants are accepted — risk of HMRC implying a substantial allocation
- Citing the case as 'Horner v Hasted' or with wrong citation — correct form: Hasted v Horner (1995) 67 TC 439
Worked example
Priya, senior executive £150,000 salary, leaving with broad non-compete + non-solicit covenants
Settlement: £40,000 PILON (PENP); £30,000 ex-gratia compensation for loss of office; £20,000 'in consideration of the restrictive covenants in clauses 8-11'.
- Step 1 — PILON £40,000: ordinary income, PAYE + NIC.
- Step 2 — Restrictive covenant £20,000: ordinary income per ITEPA s.225 and Hasted v Horner; PAYE + Class 1 employee NIC + employer NIC.
- Step 3 — Ex-gratia £30,000: within s.401, fully covered by £30k exemption — tax-free, no NIC.
- Step 4 — Compare to a poorly-drafted alternative where the £20,000 was bundled into 'compensation' (£50,000 total). HMRC would likely characterise £20,000 of that as restrictive covenant — same tax outcome but with risk of dispute, interest, and penalties on the employer for under-deduction at source.
Outcome: Priya's £30,000 ex-gratia is preserved tax-free; £60,000 of taxable income runs through PAYE; the split-line drafting is unambiguous to HMRC and avoids enquiry risk.
How this connects to the rest of the framework
Settlement-agreement drafting must split restrictive covenant consideration explicitly to preserve the £30k exemption on the ex-gratia slice.
Restrictive covenant payments are an explicit exclusion from the £30k cap.
Senior executive scenarios commonly feature substantial restrictive covenant slices alongside ex-gratia compensation.
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 avoid tax by allocating zero to restrictive covenants?+
Are confidentiality NDAs always taxable?+
Does the case Hasted v Horner still apply?+
Do restrictive covenants attract Class 1A NIC?+
Free + regulated-body resources
- HMRC EIM13630 — restrictive covenants on termination →
Authority including Hasted v Horner reference
- HMRC EIM12977 — restrictive undertakings overview →
s.225 ITEPA framework
- Employment Lawyers Association →
Specialist negotiation of restrictive covenant scope at exit
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