SCHEDULES
SCHEDULE 11Employment income provided through third parties: loans etc outstanding on 5 April 2019
PART 1Application of Part 7A of ITEPA 2003
Relevant step
F11A
1
This paragraph applies where—
a
a person (“P”) is treated as taking a relevant step within paragraph 1 (“the initial step”) by reason of making a loan or quasi-loan, and
b
an election has been made by A for the purposes of this paragraph.
2
P is treated as taking two further relevant steps for the purposes of Part 7A of ITEPA 2003.
3
P is treated as taking one of the further steps on the first anniversary of the date on which P is treated as taking the initial step.
4
P is treated as taking one of the further steps on the second anniversary of the date on which P is treated as taking the initial step.
5
For the purposes of section 554Z3(1) of ITEPA 2003 (value of relevant step), the initial step and each of the further steps is to be treated as involving a sum of money equal to one third of the amount of the loan or quasi-loan that is outstanding at the time P is treated as taking the initial step.
6
References in this Schedule and in Part 7A of ITEPA 2003 to a relevant step within paragraph 1A of this Schedule are to be read as references to a relevant step which a person is treated by this paragraph as taking.
7
An election for the purposes of this paragraph—
a
may be made at any time before 1 October 2020, and
b
may be made at a later time if an officer of Revenue and Customs allows it.
8
But a person who is under a duty imposed by paragraph 35C of this Schedule or paragraph 22 of Schedule 12 may not make an election for the purposes of this paragraph until that duty has been complied with.
9
An election for the purposes of this paragraph may not be revoked.
10
A person who has made an election for the purposes of paragraph 1(3A) of Schedule 12 is to be treated as having made an election for the purposes of this paragraph.
11
The Commissioners for Her Majesty’s Revenue and Customs may by regulations provide that sub-paragraph (7)(a) applies to a specified class of persons as if the reference to 1 October 2020 were to such later date as is specified.
12
In sub-paragraph (11) “specified” means specified in the regulations.