SAIM2050 - Interest: voluntary payments
Voluntary payments are not interest
Since interest can only accrue by virtue of some right, a voluntary or gratuitous payment cannot be interest, even if it is expressed as in lieu of or 바카라 사이트˜equivalent to half the interest바카라 사이트™, as in the case of Seaham Harbour Company v. Crook (16TC333). J Rowlatt바카라 사이트™s comment that
바카라 사이트œinterest or an annual sum which is paid really benevolently each time is merely an allowance, and not taxable at all바카라 사이트
is a reflection of that common-law principle.
Truly voluntary payments are likely to be rare. For instance where compensation is paid, labels such as 바카라 사이트˜ex gratia바카라 사이트™ may only mean that the payer settled out of court, or 바카라 사이트˜without admitting liability바카라 사이트™. Such a payment is not voluntary or gratuitous if made in consideration of the claimant giving up the right to take proceedings for the damage suffered. See SAIM2330 for more on compensation or damages generally.