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Commentary

3.6 Employment income provided through third parties

United Kingdom

Anti-avoidance provisions provide for an income tax charge to arise where third-party arrangements are used by an employer to disguise what is in substance remuneration (ITEPA 2003, Pt 7A).

The legislation applies where the arrangement relates to an existing, former or prospective employee or someone 'linked to the employee' (including non-executive directors and office holders) and provides rewards, recognition or loans in connection with employment (ITEPA 2003, s 554A).

Common examples of third-party

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