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.