The provisions in ITEPA 2003, ss 447–450 (Pt 7, Ch 4) perform something of a 'sweeping-up' function. The drafting is, presumably deliberately, broad. It is designed to encompass any benefits that are received in connection with employment-related securities, provided that such a benefit is connected with the employment, rather than ownership per se, and provided that the benefit is not otherwise chargeable to income tax (unless there is an avoidance purpose, see below).
More specifically, ITEPA 2003, ss 447–450 (Pt 7, Ch 4) applies where an associated person1 receives a benefit in connection with employment-related securities2. The securities may be owned by the recipient or by another associated person. The term 'benefit' is not given a particular definition in this context.
The charge under ITEPA 2003, ss 447–450 (Pt 7, Ch 4) does not apply if the benefit is otherwise chargeable to income tax, but this exemption is removed if something has been done which affects the securities and is part of a scheme the main purpose (or one of the
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 16:46