SCHEDULES
SCHEDULE 11Employment income provided through third parties: loans etc outstanding on 5 April 2019
PART 3Exclusions
Cases involving employment-related securities
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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 (the “relevant loan”),
b
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 of ITEPA 2003),
c
the exercise of the option by A gives rise to employment income of A in respect of A's employment with B—
i
which is chargeable to income tax or would be chargeable apart from Chapter 5B of Part 2 of ITEPA 2003, or
ii
which is exempt income, and
d
there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.