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The legislation charges payments and benefits:

1. Ìý

   (a)ÌýÌýÌýÌý made 'directly or indirectly in consideration or in consequence of, or otherwise in connection with':

2. 1. Ìý

      –ÌýÌýÌýÌý the termination of a person's employment

   2. Ìý

      –ÌýÌýÌýÌý a change in the duties of a person's employment, or

   3. Ìý

      –ÌýÌýÌýÌý a change in the earnings of a person's employment

3. Ìý

   (b)ÌýÌýÌýÌý received after 5 April 2003 by a person, their spouse or civil partner, or any blood relative or dependant, or by their personal representatives (the reference to 'relative' in ITEPA 2003 has been qualified to make it clear that only blood relatives are included; the term 'personal representatives' is as defined in ITEPA 2003, s 721(1)), and

4. Ìý

   (c)ÌýÌýÌýÌý which would not otherwise be taxed¹

The use of the phrase 'directly or indirectly … or otherwise in connection with' ensures that the charge potentially has a very wide scope. HMRC states² that the charge may apply in respect of a payment or benefit even if it:

1. Ìý

   •