E4.1065 Anti-forestalling provisions on introduction of the charge
Anti-forestalling provisions apply to certain relevant steps ('early steps') which occur on or after 9 December 2010 but before 6 April 2011, as described in this article. For the commencement provisions that would otherwise apply, see E4.1051.
Early step a payment of money
The provisions described here apply if1:
- Ìý
•ÌýÌýÌýÌý on or after 9 December 2010 but before 6 April 2011 a relevant step ('the early step') which is a payment of a sum of money within ITEPA 2003, s 554C(1)(a) (see E4.1058) is taken
- Ìý
•ÌýÌýÌýÌý the tax charge under the legislation would have applied by reason of the early step had it been taken on or after 6 April 2011, and
- Ìý
•ÌýÌýÌýÌý the early step is not chargeable to income tax by virtue of FA 2004, Sch 34 (overseas pension schemes — see E7.248) in whole or in part
In such a case, the tax charge under the disguised remuneration legislation arises on the payment
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