a person (“A”) is an employee, or a former or prospective employee, of another person (“B”),

there is an arrangement (“the relevant arrangement”) to which A is a party or which otherwise (wholly or partly) covers or relates to A,

a relevant step is taken by a relevant third person, and

A acting as a trustee,

B acting as a trustee, or

any person other than A and B.

the relevant step is connected with the relevant arrangement if (for example) the relevant step is taken (wholly or partly) in pursuance of an arrangement at one end of a series of arrangements with the relevant arrangement being at the other end, and

it does not matter if the person taking the relevant step is unaware of the relevant arrangement.

if details of the later relevant step have not been worked out (for example, details of the sum of money or asset which will or may be the subject of the step or details of how or when or by whom or in whose favour the step will or may be taken),

if any condition which would have to be met before the later relevant step is taken might never be met, or

if A, or any person linked with A, has no legal right to have a relevant step taken in relation to any sum of money or asset mentioned in subsection (1)(a)(i) or (ii) or (b)(i) or (ii) (as the case may be).

pays a sum of money to a relevant person,

transfers an asset to a relevant person,

takes a step by virtue of which a relevant person acquires an asset within subsection (4),

grants to a relevant person a lease of any premises the effective duration of which is likely to exceed 21 years.

means A or a person chosen by A or within a class of person chosen by A, and

includes, if P is taking a step on A's behalf or otherwise at A's direction or request, any other person.

securities,

interests in securities, and

securities options,

references to making a sum of money or asset available are references to making it available in any way, however informal,

it does not matter if the relevant person has no legal right to have the sum of money or asset used as mentioned, and

it does not matter if the sum of money or asset is not actually used as mentioned.

A is, or is likely to become, entitled to a later lease, or the grant of a later lease, of the same premises, or

it is otherwise likely that A will be granted a later lease of the same premises,

references to the same premises include references to any premises which include the whole or part of the same premises.

at any time, makes an asset available for a relevant person to benefit from in a way which is substantially similar to the way in which the relevant person would have been able to benefit from the asset had the asset been transferred to the relevant person at that time, or

at or after the end of the relevant period, makes an asset available for a relevant person to benefit from.

before the end of the relevant period, P makes available an asset for a relevant person to benefit from, and

at the end of the relevant period, P continues to make the asset available for the relevant person to benefit from,

references to making an asset available are references to making it available in any way, however informal,

it does not matter if the relevant person has no legal right to benefit from the asset, and

it does not matter if the relevant person does not actually benefit from the asset.

means A or a person chosen by A or within a class of person chosen by A, and

includes, if P is taking a step on A's behalf or otherwise at A's direction or request, any other person.

any limitations on the way in which the relevant person may benefit from the asset,

the period over which the asset is being made available and (if relevant) the extent to which that period covers the expected remaining useful life of the asset,

the extent to which the relevant person has, or is to have, a say over the disposal of the asset, and

the extent to which the relevant person may benefit from any proceeds arising from the disposal of the asset or otherwise have a say in the way the proceeds are used.

F2a Schedule 2 SIP (within the meaning of Chapter 6 of Part 7),

F3a Schedule 3 SAYE option scheme (within the meaning of Chapter 7 of Part 7),

F4a Schedule 4 CSOP scheme (within the meaning of Chapter 8 of Part 7),

an arrangement the sole purpose of which is the provision of excluded benefits (as defined in section 393B(3)),

an arrangement the sole purpose of which is the making of payments which are to be disregarded in the calculation mentioned in regulation 25 of the Social Security (Contributions) Regulations 2001 (S.I. 2001/1004) by virtue of paragraph 12 of Part 10 of Schedule 3 to those Regulations (as that paragraph has effect by virtue of regulation 2(3) of the Social Security (Contributions) (Amendment No. 9) Regulations 2007 (S.I. 2007/2905)),

a pension scheme set up by a government outside the United Kingdom for the benefit of its employees or primarily for their benefit,

a registered pension scheme, or

the relevant step is not taken under an arrangement mentioned in subsection (1)(a) to (c), and

there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.

the total number of shares of any type held, in relation to the F11Schedule 2 SIP, the F12Schedule 3 SAYE option scheme or the F13Schedule 4 CSOP scheme, by P and any other persons for purposes within subsection (3)(a) and (b), exceeds

the maximum number of shares of that type which might reasonably be expected to be required, in relation to the F11Schedule 2 SIP, the F12Schedule 3 SAYE option scheme or the F13Schedule 4 CSOP scheme, for those purposes over the period of ten years starting with the day on which the relevant step is taken.

there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.

the total number of shares of any type held, in relation to the EMI arrangement, by P and any other persons for purposes within subsection (6)(a)(i) to (iii), exceeds

the maximum number of shares of that type which might reasonably be expected to be required, in relation to the EMI arrangement, for those purposes over the period of ten years starting with the day on which the relevant step is taken.

a person (“P”) takes a relevant step within section 554B by reason of which Chapter 2 would apply apart from subsection (3) or (6), and

the subject of which is the sum of money or asset (or the part of it) mentioned in subsection (10)(b), and

by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

the loan is a loan on ordinary commercial terms within the meaning of section 176, ignoring conditions B and C in that section, and

there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.

the step is taken for the sole purpose of a transaction which P has with A and which P entered into in the ordinary course of P's business,

a substantial proportion of P's business involves similar transactions with members of the public,

the terms on which P entered into the transaction with A are substantially the same as the terms on which P normally enters into similar transactions with members of the public, and

there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.

the step is not taken under a pension scheme,

the step is taken for the sole purpose of a transaction which P has with A and which P entered into in the ordinary course of P's business,

the terms on which similar transactions are offered by P under the package of benefits mentioned in paragraph (c)(ii) or (d) (as the case may be) are generous enough to enable substantially all of the employees of B to whom the package is available to take advantage of what is offered (if they want to),

the terms on which P entered into the transaction with A are substantially the same as the terms on which P normally enters into similar transactions with employees of B under the package of benefits,

if B is a company, a majority of B's employees to whom the package of benefits is available do not have a material interest (as defined in section 68) in B, and

there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.

a loan is “similar” if it is made for the same or similar purposes as the loan which is the subject of the relevant step, and

“members of the public” means members of the public at large with whom P deals at arm's length.

directors,

senior employees,

employees who receive, or as a result of the package of benefits are likely to receive, the higher or highest levels of remuneration, and

on a date (“the award date”) A is awarded remuneration (“the deferred remuneration”) in respect of A's employment with B,

the main purpose of the award is not the provision of relevant benefits (within the meaning of Chapter 2 of Part 6, but ignoring section 393B(2)(a)),

the deferred remuneration is awarded on terms (“the deferred remuneration terms”) the main purpose of which is to defer the provision to A of the deferred remuneration to a specified date (“the vesting date”) which is after the award date, while providing that the award of the deferred remuneration is revoked if specified conditions are not met on or before the vesting date,

the vesting date is not more than five years after the award date,

as at the award date, there is a reasonable chance that the award of the deferred remuneration will be revoked because not all the specified conditions will be met on or before the vesting date,

if the deferred remuneration were to be provided to A by any person on the award date, that action would, for the purposes of Part 11, be a payment of PAYE employment income of A in respect of A's employment with B,

before the end of the vesting date, a person (“P”) takes a relevant step within section 554B by reason of which Chapter 2 would apply apart from this section,

on the taking of the relevant step, the sum of money or asset which is the subject of the step represents the deferred remuneration or any part of it (and nothing else), and

there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.

any sum of money or asset held by or on behalf of P on the basis mentioned in section 554B(1)(a) or (b) which represents any of the earmarked deferred remuneration ceases to represent that earmarked deferred remuneration or a part of it (because the remuneration is to be provided to A in another way or its award has been revoked or for any other reason), but

the sum of money or asset continues to be held by or on behalf of P on the basis mentioned in section 554B(1)(a) or (b).

by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

the earmarked deferred remuneration, or

the part of it to which neither subsection (10) nor subsection (11) applies,

which, at the relevant time or the end of the vesting date (as the case may be), continues to be held by or on behalf of P on the basis mentioned in section 554B(1)(a) or (b).

shares in the relevant company are admitted to trading on a stock exchange,

all the shares in the relevant company, or a substantial proportion of them, are disposed of to persons none of whom is connected with any of the persons making any disposal,

if the relevant company is a trading company (as defined in subsection (4)), the company's trade, or a substantial proportion of it, is transferred to a person who is not a relevant connected person,

the relevant company's assets, or a substantial proportion of them, are disposed of to a person who is not a relevant connected person,

the winding up of the relevant company starts, or

a person (“P”) who controls the relevant company ceases to control it, so long as no person connected with P starts to control it.

section 12(7) of CTA 2009 applies for the purpose of determining when the winding up of the relevant company starts.

the main purpose of the award of the relevant shares or sum of money would not be the provision of relevant benefits,

the award of the relevant shares or sum of money would be on terms (“the deferred award terms”) the main purpose of which is to defer the receipt of the shares by A, or the payment of the sum of money to A, to a specified date (“the vesting date”) which is after the date (“the award date”) on which the award is made, while providing that the award is revoked if specified conditions are not met on or before the vesting date,

the vesting date would not be more than ten years after the award date, and

as at the award date, there would be a reasonable chance that the award of the relevant shares or sum of money will be revoked because not all the specified conditions will be met on or before the vesting date.

the number of relevant shares of any type which are earmarked shares does not exceed the maximum number of relevant shares of that type which might reasonably be expected to be needed for meeting the award or expected award, and

there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.

the award is not made before the end of the date (“the final award date”) falling immediately after the period of three months starting with the date on which P takes the relevant step, and

as at the end of the final award date, any of the earmarked shares continue to be held by or on behalf of P solely on the basis mentioned in subsection (3)(a).

by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

any of the earmarked shares cease to be held by or on behalf of P solely on the basis mentioned in subsection (3)(a), but

the shares continue to be held by or on behalf of P on the basis mentioned in section 554B(1)(a) or (b).

by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

the relevant step mentioned in subsection (3) is taken in relation to an award which has been made as mentioned in subsection (3)(a)(i), or

the relevant step mentioned in subsection (3) is taken in relation to an expected award as mentioned in subsection (3)(a)(ii) and the award is made before the end of the final award date.

by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

A receives the shares before the end of the vesting date, and

the receipt of the shares by A gives rise to employment income of A which is chargeable to income tax or which is exempt income.

the sum of money mentioned in subsection (1)(a)(ii) (or a part of it) is paid to A before the end of the vesting date,

the payment of the sum to A gives rise to employment income of A which is chargeable to income tax or which is exempt income, and

the payment represents the proceeds of the disposal of the shares, or the payment is made from another source and, correspondingly, the shares are no longer held by any person in relation to the award.

before the end of the vesting date, the award (or any part of it) is revoked in accordance with the deferred award terms, and

correspondingly, the shares are no longer held by any person in relation to the award.

which, at the time the relevant step is treated as being taken, continues to be held by or on behalf of P on the basis mentioned in section 554B(1)(a) or (b).

the main purpose of the award would not be the provision of relevant benefits,

as at the time the award is made, there would be a reasonable chance that the specified exit event, or an exit event within the specified description, will occur.

the number of relevant shares of any type which are earmarked shares does not exceed the maximum number of relevant shares of that type which might reasonably be expected to be needed for meeting the award or expected award, and

there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.

the award is not made before the end of the date (“the final award date”) falling immediately after the period of three months starting with the date on which P takes the relevant step, and

as at the end of the final award date, any of the earmarked shares continue to be held by or on behalf of P solely on the basis mentioned in subsection (2)(a).

by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

any of the earmarked shares cease to be held by or on behalf of P solely on the basis mentioned in subsection (2)(a), but

the shares continue to be held by or on behalf of P on the basis mentioned in section 554B(1)(a) or (b).

by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

the relevant step mentioned in subsection (2) is taken in relation to an award which has been made as mentioned in subsection (2)(a)(i), or

the relevant step mentioned in subsection (2) is taken in relation to an expected award as mentioned in subsection (2)(a)(ii) and the award is made before the end of the final award date,

by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

A receives the shares before the end of the exit period, and

the receipt of the shares by A gives rise to employment income of A which is chargeable to income tax or which is exempt income.

the sum of money mentioned in subsection (1)(a)(ii) (or a part of it) is paid to A before the end of the exit period,

the payment of the sum to A gives rise to employment income of A which is chargeable to income tax or which is exempt income, and

the payment represents the proceeds of the disposal of the shares, or the payment is made from another source and, correspondingly, the shares are no longer held by any person in relation to the award.

which, at the time the relevant step is treated as being taken, continues to be held by or on behalf of P on the basis mentioned in section 554B(1)(a) or (b).

the main purpose of the grant of the relevant share option would not be the provision of relevant benefits,

the grant would be made on terms (“the deferred grant terms”) the main purpose of which is to ensure that the relevant share option is not exercisable by A before a specified date (“the vesting date”) which is after the date (“the grant date”) on which the grant is made, while providing that the relevant share option is not to be exercisable at all by A if specified conditions are not met on or before the vesting date,

the vesting date would not be more than ten years after the grant date, and

as at the grant date, there would be a reasonable chance that the relevant share option will not be exercisable at all by A because not all the specified conditions will be met on or before the vesting date.

the number of relevant shares of any type which are earmarked shares does not exceed the maximum number of relevant shares of that type which might reasonably be expected to be needed for providing shares, or paying a sum of money, pursuant to the relevant share option which is granted or expected to be granted, and

there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.

the grant is not made before the end of the date (“the final grant date”) falling immediately after the period of three months starting with the date on which P takes the relevant step, and

as at the end of the final grant date, any of the earmarked shares continue to be held by or on behalf of P solely on the basis mentioned in subsection (3)(a).

by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

any of the earmarked shares cease to be held by or on behalf of P solely on the basis mentioned in subsection (3)(a), but

the shares continue to be held by or on behalf of P on the basis mentioned in section 554B(1)(a) or (b).

by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

the relevant step mentioned in subsection (3) is taken in relation to a grant of a relevant share option made as mentioned in subsection (3)(a)(i), or

the relevant step mentioned in subsection (3) is taken in relation to an expected grant of a relevant share option as mentioned in subsection (3)(a)(ii) and the grant is made before the end of the final grant date.

by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

the relevant share option becomes exercisable (in whole or in part) by A before the end of the vesting date,

A exercises the option (wholly or partly) before the end of the final exercise date and, as a result, receives the shares, and

the relevant share option becomes exercisable (in whole or in part) by A before the end of the vesting date,

A exercises the option (wholly or partly) before the end of the final exercise date and, as a result, a sum of money is paid to A as mentioned in subsection (1)(a)(ii),

the payment represents the proceeds of the disposal of the shares, or the payment is made from another source and, correspondingly, the shares are no longer held by any person in relation to the relevant share option.

in accordance with the deferred grant terms, before the end of the vesting date, the relevant share option ceases to be exercisable by A (in whole or in part), and

correspondingly, the shares are no longer held by any person in relation to the relevant share option.

the relevant share option becomes exercisable by A (in whole or in part) before the end of the vesting date but the option lapses (in whole or in part) before the end of the final exercise date, and

correspondingly, the shares are no longer held by any person in relation to the relevant share option.

which, at the time the relevant step is treated as being taken, continues to be held by or on behalf of P on the basis mentioned in section 554B(1)(a) or (b).

the main purpose of the grant of the relevant share option would not be the provision of relevant benefits,

the grant would be made on terms (“the deferred grant terms”) the main purpose of which is to ensure that the relevant share option is exercisable by A only if a specified exit event, or an exit event within a specified description, occurs, and

as at the time the grant is made, there would be a reasonable chance that the specified exit event, or an exit event within the specified description, will occur.

the number of relevant shares of any type which are earmarked shares does not exceed the maximum number of relevant shares of that type which might reasonably be expected to be needed for providing shares, or paying a sum of money, pursuant to the relevant share option which is granted or expected to be granted, and

there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.

the grant is not made before the end of the date (“the final grant date”) falling immediately after the period of three months starting with the date on which P takes the relevant step, and

as at the end of the final grant date, any of the earmarked shares continue to be held by or on behalf of P solely on the basis mentioned in subsection (2)(a).

by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

any of the earmarked shares cease to be held by or on behalf of P solely on the basis mentioned in subsection (2)(a), but

the shares continue to be held by or on behalf of P on the basis mentioned in section 554B(1)(a) or (b).

by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

the relevant step mentioned in subsection (2) is taken in relation to a grant of a relevant share option made as mentioned in subsection (2)(a)(i), or

the relevant step mentioned in subsection (2) is taken in relation to an expected grant of a relevant share option as mentioned in subsection (2)(a)(ii) and the grant is made before the end of the final grant date,

by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

A exercises the relevant share option (wholly or partly) before the end of the exit period and, as a result, receives the shares, and

A exercises the relevant share option (wholly or partly) before the end of the exit period and, as a result, a sum of money is paid to A as mentioned in subsection (1)(a)(ii),

the payment represents the proceeds of the disposal of the shares, or the payment is made from another source and, correspondingly, the shares are no longer held by any person in relation to the relevant share option.

the relevant share option becomes exercisable by A before the end of the exit period but the option lapses (in whole or in part) at or before the end of that period, and

correspondingly, the shares are no longer held by any person in relation to the relevant share option.

the period of six months starting with the date on which the exit event occurs, or

if it ends earlier, the period during which the relevant share option is exercisable by A in accordance with the deferred grant terms.

which, at the time the relevant step is treated as being taken, continues to be held by or on behalf of P on the basis mentioned in section 554B(1)(a) or (b).

by virtue of the step, the securities are acquired by a person, and

section 425(2) applies, or would apply apart from section 421E(1), to the acquisition.

by virtue of the step, the option is acquired by a person, and

section 475(1) applies, or would apply apart from section 474(1), to the acquisition.

a chargeable event for the purposes of section 426, 438 or 476,

an event which gives rise to the discharge of a notional loan for the purposes of section 446U, or

a disposal to which Chapter 3D of Part 7 applies.

relevant consideration is given by A for the relevant asset of an amount equal to or greater than the market value of the relevant asset at the time of the acquisition, or

there is an acquisition of an asset within section 554C(4)(a) or (b) (“the relevant asset”),

the acquisition is pursuant to an employment-related securities option (within the meaning of Chapter 5 of Part 7, but ignoring section 474(1)) acquired by reason of A's employment, or former or prospective employment, with B, and

the acquisition is a chargeable event for the purposes of section 476 or would be a chargeable event apart from section 474(1).

the subject of the relevant step is the relevant asset, and

there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.

the payment of the sum of money is by way of a loan (“the relevant loan”),

the relevant loan is made and used solely for the purpose of enabling A to exercise an employment-related securities option (within the meaning of Chapter 5 of Part 7),

there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.

apart from subsection (13), Chapter 2 would apply by reason of the relevant step mentioned in that subsection, and

by the end of the relevant period, the relevant loan has not been fully repaid.

the subject of which is a sum of money of an amount equal to the outstanding amount of the relevant loan as at the end of the relevant period,

in relation to which the relevant person (within the meaning of section 554C(1)) is the person to whom the relevant loan is made, and

by reason of which Chapter 2 is to apply.

as provided for by the car ownership arrangement, A purchases the car using the car loan.

the purchase of the car or its sale-back as provided for by the car ownership arrangement, or

the making of the car loan as so provided,

apart from subsection (2), Chapter 2 would apply by reason of the making of the car loan, and

by the end of the repayment date, the car loan has not been fully repaid.

the subject of which is a sum of money of an amount equal to the outstanding amount of the car loan as at the end of the repayment date,

in relation to which the relevant person (within the meaning of section 554C(1)) is A, and

by reason of which Chapter 2 is to apply.

section 22 of the 2000 Act,

any relevant order under that section, and

Schedule 2 to that Act.

one in relation to the subject of the step so far as the exemption applies to it, and

one in relation to the subject of the step so far as the exemption does not apply to it,

a sum of money or asset (“sum or asset R”) is held by or on behalf of a person (“P”),

income arises from sum or asset R, and

before the income arises, sum or asset R was the subject of a relevant step within section 554B taken by P,

Chapter 2 applied by reason of the relevant step mentioned in paragraph (a) in respect of A's employment with B or would have so applied apart from this section or section 554R or any of sections 554H to 554M or section 554T,

immediately before the income arises, sum or asset R is still earmarked or otherwise held on the basis mentioned in section 554B(1)(a) or (b), and

subsection (3) does not apply.

a sum of money or asset (“sum or asset S”) is held by or on behalf of a person (“P”),

a sum of money or asset (“sum or asset T”) is acquired by or on behalf of P wholly out of sum or asset S,

sum or asset T is not acquired (directly or indirectly) from A or any person linked with A, and

subsection (2) does not apply.

at the time of the acquisition of sum or asset T, the value of sum or asset T is greater or less than the value of sum or asset S, and

the difference (or any part of the difference) in the values might not have been expected applying the assumption that all relevant connected persons are acting at arm's length of each other.

the reference to sum or asset S is to sum or asset S so far as sum or asset T is acquired out of it, and

“relevant connected person” means a person with a connection (direct or indirect) to the arrangement under which sum or asset T is acquired.

before the acquisition, sum or asset S was the subject of a relevant step within section 554B taken by P,

Chapter 2 applied by reason of the relevant step mentioned in paragraph (a) in respect of A's employment with B or would have applied apart from this section or section 554Q or 554T, and

immediately before the acquisition, sum or asset S is still earmarked or otherwise held on the basis mentioned in section 554B(1)(a) or (b).

for the sole purpose of the acquisition, sum or asset S or sum or asset T is the subject of a relevant step within section 554C(1)(a) to (c).

one in relation to the sum of money or asset so far as it arises or derives from the excluded pension contribution, and

one in relation to the sum of money or asset so far as it does not arise or derive from the excluded pension contribution,

represents relevant benefits, and

arises or derives (whether wholly or partly or directly or indirectly) from an excluded pension contribution paid by A.

one in relation to the sum of money or asset so far as it arises or derives from the excluded pension contribution, and

one in relation to the sum of money or asset so far as it does not arise or derive from the excluded pension contribution,

which is made to an arrangement by A by way of a payment of a sum of money,

by virtue of which A acquires rights to receive relevant benefits under the arrangement (and nothing else),

which is neither a relievable pension contribution nor a tax-relieved contribution, and

which is not a repayment of any loan and otherwise has nothing to do with any loan and has nothing to do with a sum of money or asset which has been the subject of a relevant step within section 554C(1)(d).

which was paid by B in accordance with an employer-financed retirement benefits scheme (within the meaning of Chapter 2 of Part 6) with a view to the provision of benefits under the scheme, and

in respect of which A is taxed.

one in relation to the sum of money or asset so far as it arises or derives from the taxed sum, and

one in relation to the sum of money or asset so far as it does not arise or derive from the taxed sum,

an annuity contract is purchased from an insurance company wholly out of rights which A has under a pension scheme, and

A's rights out of which the annuity contract is purchased are, wholly or partly, pre-6 April 2011 annuity rights.

takes a relevant step for the sole purpose of purchasing the annuity contract or transferring the beneficiary's rights under the annuity contract to A or a person linked with A, or

on the purchase of the annuity contract, otherwise takes a relevant step within section 554B the subject of which is the beneficiary's rights under the annuity contract,

takes a relevant step for the sole purpose of selling the annuity contract, or

on the sale of the annuity contract, otherwise takes a relevant step within section 554B the subject of which is a sum of money or asset representing the purchase price received for the annuity contract,

one in relation to the annuity contract so far as it is purchased out of rights which are pre-6 April 2011 annuity rights, and

one in relation to the annuity contract so far as it is purchased out of rights which are not pre-6 April 2011 annuity rights,

a relevant benefit is provided under a relevant scheme by way of a payment of a lump sum wholly out of rights which A has under the scheme,

A's rights out of which the lump sum is paid are, wholly or partly, pre-6 April 2011 lump sum rights, and

the payment of the lump sum is a relevant step within section 554C.

one in relation to the lump sum so far as it is paid out of rights which are pre-6 April 2011 lump sum rights, and

one in relation to the lump sum so far as it is paid out of rights which are not pre-6 April 2011 lump sum rights,

rights which A has under an overseas pension scheme are transferred to another overseas pension scheme, and

some or all of the rights transferred are section 390 scheme rights.

a relevant step within section 554C taken for the sole purpose of transferring the rights, or

a relevant step within section 554B taken by the transferee in relation to the transferred rights on their transfer.

one in relation to the section 390 scheme rights, and

one in relation to the rest of the transferred rights,

are paid by B on or after 6 April 2006, and

are neither tax-relieved contributions nor tax-exempt provision.

one in relation to the rights mentioned in subsection (7), and

one in relation to the rest of the transferred rights,

in subsection (7) the reference to the transferred rights is to be read as a reference to the transferred section 390 scheme rights only, and

in subsections (8) and (9) references to any relevant step mentioned in subsection (3) are to be read as references to the separate relevant step mentioned in subsection (5)(a).

by reason of a relevant step falling within a specified description, or

in the cases otherwise specified in the regulations.

make other provision modifying the application of any provision of this Part.

a step within section 554B where the subject of the relevant step is a sum of money,

a step within section 554C(1)(a), or

a step within section 554C(1)(d) where the subject of the relevant step is a sum of money.

it does not matter if the person taking the step is unaware of the tax avoidance arrangement.

any person who is or has been connected with A,

a close company in which A or a person within any other paragraph of this subsection is or has been a participator,

a company in which A or a person within any other paragraph of this subsection is or has been a participator and which would be a close company if it were a UK resident company, or

a company which is a 51% subsidiary of a company within paragraph (b) or (c).

a man and woman living together as if they were spouses of each other are treated as if they were spouses of each other, and

two people of the same sex living together as if they were civil partners of each other are treated as if they were civil partners of each other.

in relation to a close company, means a person who is a participator in relation to the company for the purposes of section 455 of CTA 2010 (see sections 454 and 455(5) of that Act), and

in relation to a company which would be a close company if it were a UK resident company, means a person who would be such a participator if the company were a close company.

if the relevant step is taken before A's employment with B starts, for the tax year in which the employment starts, or

otherwise, for the tax year in which the relevant step is taken.

an amount which (apart from this subsection) would be treated as earnings of A under a provision of the benefits code, or

any income of A which (apart from this subsection) would be dealt with under Chapter 3 of Part 4 of ITTOIA 2005,

the market value when the relevant step is taken of the asset which is the subject of the step, or

if higher, the cost of the relevant step.

the relevant step is within section 554C(1)(c), and

any of Chapters 2 to 4A of Part 7 apply by virtue of the acquisition.

a tax year for which A is non-UK resident, or

a tax year that is a split year as respects A.

in a case within subsection (3)(a), by so much of the value, or the part of it, as is not in respect of UK duties, and

the value, or the part of it, is not in respect of UK duties, or

so much of the value, or the part of it, as is attributable to the overseas part of the tax year is not in respect of UK duties,

it is the payment of a lump sum to a relevant person (see section 554C(2)),

the lump sum is a relevant benefit provided under a relevant scheme,

the step is taken in the temporary period of non-residence, and

when an individual is to be regarded as “temporarily non-resident”, and

what “the temporary period of non-residence” and “the period of return” mean.

the sum of money or asset (“sum or asset P”) which is the subject of the relevant step, and

the sum of money or asset (“sum or asset Q”) which was the subject of an earlier relevant step (“the earlier relevant step”) by reason of which this Chapter applied in respect of A's employment with B.

if the overlap covers the whole of sum or asset Q, by the value of the earlier relevant step, or

if the overlap covers only part of sum or asset Q, by the part of the value of the earlier relevant step which corresponds to the part of sum or asset Q covered by the overlap as determined on a just and reasonable basis.

after any reductions made to it under section 554Z4 or this section or section 554Z7, but

before any reductions made to it under section 554Z6 or 554Z8.

they are the same sum of money or asset, or

sum or asset P, essentially, replaces sum or asset Q.

which are, in accordance with section 16 and (if applicable) section 17, “for” a tax year in which A is UK resident F22(and, in the case of a tax year that is a split year as respects A, are not “excluded” by virtue of section 15(1A)(a) and (b)(i)), or

which are, in accordance with section 29 and (if applicable) section 30, “for” a tax year in which A is non-UK resident but which are in respect of duties performed in the United Kingdom for the purposes of section 27(1)(a).

earnings within Chapter 1 of Part 3,

amounts treated as earnings under Chapter 12 of Part 3, and

a deemed employment payment under section 50 or any part of such a payment.

the relevant step is a step within section 554B (other than one treated as being taken by section 554L(5), (7) or (9) or 554M(4), (6) or (8)),

B is a company,

the number of relevant shares of any type which are earmarked shares does not exceed the maximum number of relevant shares of that type which might reasonably be expected to be needed for providing shares, or paying a sum of money, pursuant to the relevant share option which is granted or expected to be granted, and

there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.

the relevant step is a step treated as being taken by section 554L(9) or 554M(8), and

the amount of the sum of money which A would have to pay as mentioned in subsection (1)(d) or (2)(b), or

if the value of the relevant step was reduced under section 554Z4, X% of the amount of that sum of money.

the grant is not made before the end of the date (“the final grant date”) falling immediately after the period of three months starting with the date on which the relevant step is taken, and

as at the end of the final grant date, any of the earmarked shares continue to be held by or on behalf of P solely on the basis mentioned in subsection (1)(e).

any of the earmarked shares cease to be held by or on behalf of P solely on the basis mentioned in subsection (1)(e), but

the shares continue to be held by or on behalf of P on the basis mentioned in section 554B(1)(a) or (b).

the subject of which is the earmarked shares mentioned in subsection (5)(b) or (6), and

by reason of which this Chapter is to apply (subject only to section 554A(4)).

the relevant step is a step within section 554C(1)(a) to (c),

the relevant step is for consideration given by A in the form of the transfer of an asset to P from A,

the transfer by A of the asset is made before, or at or about, the time the relevant step is taken and is not by way of a loan, and

there is no connection (direct or indirect) between the transfer by A of the asset and a tax avoidance arrangement.

the market value of the asset transferred by A at the time of its transfer, or

if the value of the relevant step was reduced under section 554Z4, X% of that market value.

before the transfer, the asset was transferred to A by another person by way of a loan, or

the asset is, or carries with it, any rights or interests under the relevant arrangement or any arrangement which is connected (directly or indirectly) with the relevant arrangement.

the relevant step is a step within section 554C(1)(b) or (c) or (e) or 554D and does not also involve a sum of money,

the relevant step is for consideration given by A in the form of the payment of a sum of money to P by A, and

the payment is made before, or at or about, the time the relevant step is taken.

the amount of the consideration given, or

if the value of the relevant step was reduced under section 554Z4, X% of the amount of that consideration.

the value of the relevant step, or a part of it, is “for” a tax year (“the relevant tax year”) as determined under section 554Z4,

section 809B, 809D or 809E of ITA 2007 (remittance basis) applies to A for the relevant tax year,

A does not meet the requirement of section 26A for the relevant tax year (reading references there to the employee as references to A),

A's employment with B in the relevant tax year is employment with a foreign employer, and

the duties of A's employment with B in the relevant tax year are performed wholly outside the United Kingdom.

A has associated employments, and

the duties of the associated employments are not performed wholly outside the United Kingdom.

A's employment income for the relevant tax year from all associated employments, together with A's employment with B,

the proportion of that income F26(or of so much of it as is attributable to the UK part of the relevant tax year, if it was a split year as respects A) which is general earnings to which section 22 applies or is employment income to which section 41A applies,

the nature of and time devoted to the duties performed outside the United Kingdom, and those performed in the United Kingdom, in the relevant tax year F27(or the UK part of it), and

all other relevant circumstances,

the value of the relevant step, or a part of it, is “for” a tax year (“the relevant tax year”) as determined under section 554Z4,

section 809B, 809D or 809E of ITA 2007 (remittance basis) applies to A for the relevant tax year, and

A meets the requirement of section 26A for the relevant tax year (reading references there to the employee as references to A).

A's employment income by virtue of section 554Z2(1), or

the relevant part of A's employment income by virtue of that section,

the employment income, or the relevant part of it, is not in respect of UK duties, or

so much of the employment income, or of the relevant part of it, as is attributable to the UK part of the relevant tax year is not in respect of UK duties,

after the relevant step is taken, there is another relevant step (“the later relevant step”) by reason of which this Chapter applies in respect of A's employment with B, and

within the meaning of section 554Z5, there is overlap between the sum of money or asset (“sum or asset R”) which is the subject of the relevant step and the sum of money or asset (“sum or asset S”) which is the subject of the later relevant step.

sum or asset S and sum or asset R are the same sum of money or asset, or

sum or asset S derives from sum or asset R,

the relevant tax year within the meaning of section 554Z9 or 554Z10 is the tax year 2007-08 or any earlier tax year, and

it is all or part of a relevant benefit provided to a relevant person (see section 554C(2)) under a relevant scheme,

it is provided in the form of the lump sum,

it is remitted to the United Kingdom in the temporary period of non-residence, and

when an individual is to be regarded as “temporarily non-resident”, and

what “the temporary period of non-residence” and “the period of return” mean.

the relevant step is taken on or after A's death, or

if relevant, any of A's employment income by virtue of section 554Z2(1) is remitted to the United Kingdom on or after A's death.

A's employment income by virtue of section 554Z2(1), or

so much of that income as is remitted.

counts as employment income of A, or

is remitted,

counts as employment income of A, or

is remitted.

if the person (or any of the persons) who took the relevant step is UK resident, “the relevant taxable person” is the person (or each of the UK resident persons) who took the relevant step,

if paragraph (a) does not apply and B is still alive or in existence when the relevant step is taken, “the relevant taxable person” is B, or

if neither paragraph (a) nor paragraph (b) applies, “the relevant taxable person” is the non-UK resident person (or each of the non-UK resident persons) who took the relevant step.

the rate of tax is the rate applying for the purposes of section 394(2) (see section 394(4)) at the time of the relevant step or remittance of income, and

the tax is charged for the tax year in which the relevant step is taken or the income is remitted.

counts as employment income of A, or

is remitted,

after the relevant step is taken, another event (“the later event”) occurs,

it is just and reasonable for this section to apply in order to avoid a double charge to income tax in respect of the sum of money or asset which is the subject of the relevant step.

this Chapter has applied by reason of a relevant step (“the original relevant step”) within section 554B taken by a person (“P”),

there occurs an event (“the relevant event”) which is not a relevant step in relation to a relevant sum or asset,

by reason of the relevant event no further relevant step is or will be taken by P or any other person in relation to any relevant sum or asset, and

there is no connection (direct or indirect) between the relevant event and a tax avoidance arrangement.

the sum of money or asset which is the subject of the original relevant step, or

a sum of money or asset which (directly or indirectly) has arisen or derived, or may arise or derive, from the sum of money or asset mentioned in paragraph (a).

the amount which counted as employment income of A under this Chapter as a result of this Chapter applying by reason of the original relevant step, or

any amount treated by section 222 as earnings of A in relation to the notional payment (within the meaning of that section) which B is treated as having made by virtue of the original relevant step.