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Contents

Official guidance
Employment Income Manual

EIM45000 · Employment income provided through third parties: overview, general approach

  • EIM45001 · Employment income provided through third parties: Summary of structure of guidance
  • EIM45005 · Employment income provided through third parties: requests for clearance
  • EIM45010 · Employment income provided through third parties: glossary
  • EIM45025 · Employment income provided through third parties: the Section 554A gateway: examples: dividends
  • EIM45030 · Employment income provided through third parties: the section554A gateway: all the relevant circumstances
  • EIM45035 · Employment income provided through third parties: meaning of ‘relevant third person’
  • EIM45045 · Employment income provided through third parties: meaning of 'relevant third person': group exception: examples
  • EIM45050 · Employment income provided through third parties: meaning of 'relevant third person': LLP exception: examples
  • EIM45055 · Employment income provided through third parties: relevant steps: how Sections 554B to 554D are related
  • EIM45060 · Employment income provided through third parties: relevant steps: Section 554C: overview
  • EIM45065 · Employment income provided through third parties: relevant steps: section 554C: payment of sum of money
  • EIM45070 · Employment income provided through third parties: relevant steps: Section 554C: sum of money or asset made available
  • EIM45075 · Employment income provided through third parties: relevant steps: Section 554C: grant of lease
  • EIM45080 · Employment income provided through third parties: relevant steps: Section 554D: making asset available for relevant person to benefit from
  • EIM45085 · Employment income provided through third parties: relevant steps: Section 554D: asset made available: events before 6 April and after 5April 2011: examples
  • EIM45090 · Employment income provided through third parties: relevant steps: ‘relevant person’ in sections 554C and 554D
  • EIM45095 · Employment income provided through third parties: relevant steps: Section 554B: earmarking etc of sum of money or asset
  • EIM45100 · Employment income provided through third parties: Section554B: earmarking etc of sum of money or asset: relevant third person not aware of all the facts
  • EIM45105 · Employment income provided through third persons: relevant steps: Section 554B: earmarking etc of sum of money or asset: employee share scheme: shares from various sources
  • EIM45106 · Employment income provided through third parties: relevant steps: Section 554B: earmarking etc of sum of money or asset: employee share scheme: using options to hedge share awards
  • EIM45110 · Employment income provided through third parties: relevant steps: Section 554B: meaning of 'earmarked' in Section 554B(1)(a)
  • EIM45115 · Employment income provided through third parties: relevant steps: relevant step within Section 554B, later relevant step within Section554C or 554D, exclusions within Section 554E onwards
  • EIM45120 · Employment income provided through third parties: the Section554A gateway: examples: loans
  • EIM45125 · Employment income provided through third parties: the Section554A gateway: examples: EBTs
  • EIM45130 · Employment income provided through third parties: the Section554A gateway: examples: various
  • EIM45131 · Employment income provided through third parties: the Section 554A gateway: examples: various (2)
  • EIM45135 · Employment income provided through third parties: the Section 554A gateway: examples: dividends
  • EIM45140 · Employment income provided through third parties: undertakings given by employers etc in relation to retirement benefits etc: overview
  • EIM45145 · Employment income provided through third parties: undertakings given by employers etc in relation to retirement benefits etc: conditions
  • EIM45150 · Employment income provided through third parties: undertakings given by employers etc in relation to retirement benefits etc: earmarking etc by B
  • EIM45155 · Employment income through third parties: undertakings given by employers etc in relation to retirement benefits etc: provision of security by employers etc
  • EIM45160 · Employment income provided through third parties: undertakings given by employers etc in relation to retirement benefits etc: transition
  • EIM45165 · Employment income provided through third parties: undertakings given by employers etc in relation to retirement benefits etc: examples
  • EIM45200 · Employment income provided through third parties: exclusions: general
  • EIM45300 · Employment income provided through third parties: exclusions: share schemes etc
  • EIM45600 · Employment income provided through third parties: exclusions: retirement benefits etc
  • EIM45700 · Employment income provided through third parties: Part 7A income
  • EIM45800 · Employment income provided through third parties: remittance basis
  • EIM45900 · Employment income provided through third parties: transitional rules
  • EIM46000 · Part 7A ITEPA 2003 - Finance Act 2017 amendments: introduction
  • EIM46001 · Double taxation provisions: Finance Act 2017
  • EIM47000 · Loans etc outstanding on 5 April 2019: loan charge
  1. Employment income provided through third parties: overview, general approach: contents
  2. Employment income provided through third parties: glossary

EIM45010 | Employment income provided through third parties: glossary

From HM Revenue & Customs · Employment Income Manual

A, B and PIn this guidance (as in Part 7A ITEPA 2003):\nA is the employee (or former or prospective employee) mentioned in Section 554A(1)(a),\nB is A’s employer (or former or prospective employer), and\n(unless otherwise specified) P is the person taking the step under review.
‘Arrangement’ and ‘taxavoidance arrangement’‘Arrangement’ and ‘tax avoidance arrangement’ are statutory terms: see EIM45855.
Earmarking‘Earmarked’ is the key term in Section 554B(1)(a), one of the provisions which define ‘relevant step’.\nSee EIM45095 onwards.
EBTEmployee benefit trust. This is just one example of a trust and any other sort of trust could be involved in arrangements that are covered by Part 7A.
EFRBSEmployer-financed retirement benefits scheme. See Part 6 Chapter 2 ITEPA 2003 and EIM15010 onwards.
Exit eventFor the meaning of ‘exit event’ in Sections 554K and 554M, see EIM45465.
‘Linked’ with A‘Linked’ with A is a statutory term: see EIM45860.
Part 7A incomeThis guidance refers to employment income under Part 7A ITEPA 2003 as ‘Part 7A income’ for short.
The Part 7A rulesThis guidance refers to the legislation on employment income provided through third parties, introduced by Schedule 2 FA 2011 and chiefly contained in Part 7A ITEPA 2003, as ‘the Part 7A rules’ for short.\nYou may find that some people refer to the Part 7A rules as the ‘disguised remuneration’ regime.
Relevant incomeFor the meaning of ‘relevant income’ in Sections 554J to 554M, see EIM45475.
Relevant personA relevant step within Section 554C or 554D is taken in favour of a ‘relevant person’.\nSee EIM45090.
Relevant sharesFor the meaning of ‘relevant shares’ in Sections 554J to 554M and 554Z7, see EIM45480.
Relevant stepA relevant step is an action which gives rise to Part7A income by reason of A’s employment with B.\nThe amount of the Part 7A income is the value of the relevant step (adjusted as appropriate).\nSee EIM45055 onwards.
Relevant third personA relevant step only gives rise to Part 7A income if it is taken by a ‘relevant third person’.\nSee EIM45035.
Section 554A gatewayThe conditions in Section 554A(1) must be met before an arrangement can give rise to Part 7A income.\nThis guidance refers to meeting these conditions as ‘coming through the Section 554A gateway’. See EIM45025.
Section 554*Part 7A ITEPA 2003 comprises Sections 554A to 554Z21.\nIn this guidance, any reference to a section number (without specifying the Act it relates to) is to that section of ITEPA 2003.\nFor example, ‘Section 554P’ is a reference to Section 554P ITEPA2003.
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