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Official guidance
Employment Income Manual

EIM45200 · Employment income provided through third parties: exclusions: general

  • EIM45201 · Employment income provided through third parties: summary of structure of guidance on exclusions
  • EIM45205 · Employment income provided through third parties: exclusions: commercial loans
  • EIM45210 · Employment income provided through third parties: exclusions: commercial transactions other than loans
  • EIM45215 · Employment income provided through third parties: exclusions: employee benefit packages: general
  • EIM45220 · Employment income provided through third parties: exclusions: employee benefit packages: transaction is loan
  • EIM45225 · Employment income provided through third parties: exclusions: employee benefit packages: transaction is not loan
  • EIM45230 · Employment income provided through third parties: exclusions: employee car ownership schemes: conditions
  • EIM45235 · Employment income provided through third parties: exclusions: employee car ownership schemes: relief
  • EIM45240 · Employment income provided through parties: exclusions: employment income exemptions
  • EIM45245 · Employment income provided through third parties: exclusions: income arising from earmarked sum or asset
  • EIM45250 · Employment income provided through third parties: exclusions: acquisitions out of earmarked sums or assets
  • EIM45255 · Employment income provided through third parties: exclusions: earmarking of deferred remuneration: conditions
  • EIM45260 · Employment income provided through third parties: exclusions: earmarking of deferred remuneration: conditions: examples
  • EIM45265 · Employment income provided through third parties: exclusions: earmarking of deferred remuneration: continued earmarking
  • EIM45270 · Employment income provided through third parties: exclusions: earmarking of deferred remuneration: fall-back charge
  • EIM45275 · Employment income provided by third parties: exclusions: holiday pay schemes
  1. Employment income provided through third parties: exclusions: general: contents
  2. Employment income provided through third parties: exclusions: commercial transactions other than loans

EIM45210 | Employment income provided through third parties: exclusions: commercial transactions other than loans

From HM Revenue & Customs · Employment Income Manual

Section 554F ITEPA 2003

If an arrangement comes through the Section 554A gateway, and the relevant step is not a payment of a sum of money by way of loan, Section 554F(2) prevents the step from giving rise to Part 7A income if four conditions are met.

  • The step is taken for the sole purpose of a transaction which:

  • the person (P) taking the step has with A, and

  • P entered into in the ordinary course of P’s business.

  • A substantial proportion of P’s business involves similar transactions with members of the public at large with whom P deals at arm’s length.

  • The terms on which P entered into the transaction with A are substantially the same as the terms on which P normally enters into similar transactions with members of the public with whom P deals at arm’s length. A transaction is ‘similar’ if it is of the same type as, or a similar type to, P’s transaction with A.

  • There is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement (see EIM45855).

For the purposes of Section 554F, ‘A’ includes persons linked with A. See EIM45860.

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