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The provisions described in this article¹ set out the circumstances in which the charging provisions in ITEPA 2003, Pt 7A, Ch 2 (ss 554Z2–554Z15) apply. They introduce the concept of 'relevant steps' (taken in pursuance of, or connected to, 'relevant arrangements') the value of which will count as employment income of the employee, or prospective or former employee, of another person.

The charge to tax is made if²:

1. Ìý

   (a)ÌýÌýÌýÌý a person (A) is a present, former or prospective employee of another person (B)

2. Ìý

   (b)ÌýÌýÌýÌý there is an arrangement ('the relevant arrangement') to which A is a party or which otherwise (wholly or partly) covers A or relates to A

3. Ìý

   (c)ÌýÌýÌýÌý it is reasonable to suppose that the relevant arrangement (or so much of it as relates to A) is (wholly or partly) a means of providing rewards or recognition or loans in connection with A's employment (current, former or prospective) with B (or is otherwise concerned (wholly or partly) with the provision of such rewards etc)

4. Ìý

   (d)