Disguised remuneration tax legislation (Part 7A of ITEPA 2003): issues for share plans and other employee benefits

Resource type: Practice note

Status: Maintained

Jurisdiction: United Kingdom

Part 7A of Income Tax (Earnings and Pensions) Act 2003 counters tax avoidance using employee benefit trusts and other intermediaries to reward employees or their family members, but is very broadly drafted. This note considers the scope of the legislation, HMRC's guidance about it and how it applies in practice, and highlights some practical difficulties it may cause for share and bonus schemes which are not avoidance schemes.

PLC Share Schemes & Incentives

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Resource ID: 4-504-5317
Products: PLC UK Pensions, PLC UK Share Schemes & Incentives
This resource is maintained, meaning that we monitor developments on a regular basis and update it as soon as possible.

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Topics

Employee Benefit TrustsEmployee Benefit Trusts (http://uk.practicallaw.com/9-205-7170)
Tax and NICs for IncentivesTax and NICs for Incentives (http://uk.practicallaw.com/6-205-7176)

Practice note: overview

Disguised remuneration tax legislation (rewards from third parties, Part 7A of ITEPA 2003): an overview Disguised remuneration tax legislation (rewards from third parties, Part 7A of ITEPA 2003): an overview (http://uk.practicallaw.com/topic2-506-7659)
Disguised remuneration tax rules and employee share plans: a quick guide Disguised remuneration tax rules and employee share plans: a quick guide (http://uk.practicallaw.com/topic7-505-6899)
Employee benefit trusts: an overview Employee benefit trusts: an overview (http://uk.practicallaw.com/topic1-500-3984)
Employee share schemes: an introduction Employee share schemes: an introduction (http://uk.practicallaw.com/topic9-107-4444)
Joint ownership arrangements: an overview Joint ownership arrangements: an overview (http://uk.practicallaw.com/topic5-520-2316)
Sourcing shares for share plans: an overview Sourcing shares for share plans: an overview (http://uk.practicallaw.com/topic8-205-0145)

Practice note

Disguised remuneration rules (Part 7A, ITEPA 2003): legislation tracker Disguised remuneration rules (Part 7A, ITEPA 2003): legislation tracker (http://uk.practicallaw.com/topic2-505-5944)

Article

Part 7A ITEPA 2003: practitioners' views Part 7A ITEPA 2003: practitioners' views (http://uk.practicallaw.com/topic3-508-2720)

Legal update: archive

Ask the team: Employee options to purchase a shareholder's issued shares: disguised remuneration issues Ask the team: Employee options to purchase a shareholder's issued shares: disguised remuneration issues (http://uk.practicallaw.com/topic5-506-1627)
Ask the team: Leaving shares to employees in a will: disguised remuneration issues Ask the team: Leaving shares to employees in a will: disguised remuneration issues (http://uk.practicallaw.com/topic9-509-3259)
Guidance on disguised remuneration published in HMRC Employment Income Manual: share schemes aspects Guidance on disguised remuneration published in HMRC Employment Income Manual: share schemes aspects (http://uk.practicallaw.com/topic5-510-2109)
HMRC offers to settle disputes over disguised remuneration for tax years before 2011-12 HMRC offers to settle disputes over disguised remuneration for tax years before 2011-12 (http://uk.practicallaw.com/topic3-505-8070)
New HMRC avoidance spotlight on employee benefit trusts New HMRC avoidance spotlight on employee benefit trusts (http://uk.practicallaw.com/topic8-505-0076)

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