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Home / Simons-Taxes /Personal and employment tax /Part E4 Employment income /Division E4.5 Income and exemptions relating to securities /Notional loan provisions for employment related securities acquired for less than market value / E4.507W Operation of the notional loan charge on securities acquired at less than market value
Commentary

E4.507W Operation of the notional loan charge on securities acquired at less than market value

Personal and employment tax

Once the provisions of ITEPA 2003, ss 446Q–446W (Pt 7, Ch 3C) are triggered (see E4.507V), an interest-free loan (the 'notional loan') is treated as having been made to the employee by the employer at the time of acquisition1. The consequences of an employment-related loan are then imported2, see E4.640 onwards. Specifically, these are3:

  1. Ìý

    •ÌýÌýÌýÌý the treatment of the benefit of a cheap loan as earnings (under ITEPA 2003, s 175)

  2. Ìý

    •ÌýÌýÌýÌý the exception for loans where interest qualifies for tax relief (ITEPA 2003, s 178)

  3. Ìý

    •ÌýÌýÌýÌý the threshold for the benefit of a loan to be treated as earnings (ITEPA 2003, s 180)

  4. Ìý

    •ÌýÌýÌýÌý the normal, averaging method of calculating the benefit (ITEPA 2003, s 182)

  5. Ìý

    •ÌýÌýÌýÌý the alternative method of calculation (ITEPA 2003, s 183)

  6. Ìý

    •ÌýÌýÌýÌý interest treated as paid (ITEPA 2003, s 184)

  7. Ìý

    •ÌýÌýÌýÌý the apportionment of the cash equivalent in the case

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