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Relevant step taken after A's death

There are provisions¹ that deal in detail with who is liable for the tax under the legislation on relevant steps within ITEPA 2003, ss 554C and 554D ('Payment of sum, transfer of asset etc' and 'Making asset available' in E4.1058) taken after the death of A (the employee in E4.1052) or where the remittance basis applies and any of the employment income arising to A under these provisions is remitted to the UK on or after A's death. The provisions do not apply where the relevant step is within (a) or (b) under 'Earmarking etc of sum of money or asset' or (ab) under 'Payment of sum, transfer of asset etc' in E4.1058.

There is no liability if A dies before commencing employment with B². The temporary non-residence anti-avoidance provisions described in E4.1054 and E4.1055 apply, unless the relevant person's temporary non-residence began before A died³.

Avoidance of double tax charge—earlier income tax liability

ITEPA 2003, ss 554Z11B–554Z11G deal with the possibility of