SCHEDULES

SCHEDULE 11Employment income provided through third parties: loans etc outstanding on 5 April 2019

PART 3Exclusions

Commercial transactions

25

Chapter 2 of Part 7A of ITEPA 2003 does not apply by reason of a relevant step within paragraph 1 which is treated as being taken by a person (“P”) if—

(a)

P is treated as taking a relevant step by that paragraph by reason of the payment of a sum of money by way of a loan,

(b)

the loan is (at the time it is made) a loan on ordinary commercial terms within the meaning of section 176 of ITEPA 2003, ignoring conditions B and C in that section, and

(c)

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