SCHEDULES
SCHEDULE 11Employment income provided through third parties: loans etc outstanding on 5 April 2019
PART 1Application of Part 7A of ITEPA 2003
Meaning of “outstanding”: loans
5
1
This paragraph applies where—
a
a person (“P”) has made a loan to a relevant person,
b
the loan was made on or after F19 December 2010, and
c
before the end of 5 April 2019, A or B acquires (whether or not for consideration) a right to payment of the whole or part of the loan.
2
The amount of the loan in respect of which A or B acquires a right to payment is to be treated—
a
for the purposes of paragraph 1(1) as an amount, of the loan made by P to the relevant person, that is outstanding immediately before the end of 5 April 2019;
b
for the purposes of F2paragraphs 1(4) and 1A(5) and section 554Z3(1) of ITEPA 2003, as an amount of the loan that is outstanding at the time P is treated as taking the relevant step under paragraph 1(1).
3
Where a quasi-loan or a loan made by P to a relevant person is replaced, directly or indirectly, by a loan or another loan (the “replacement loan”), references in sub-paragraphs (1) and (2) to the loan are references to the replacement loan.