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SCHEDULES

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

PART 4U.K.Supplementary provision

Remittance basisU.K.

39U.K.Part 7A of ITEPA 2003 is amended as follows.

40(1)Section 554Z9 (remittance basis: A does not meet section 26A requirement) is amended in accordance with this paragraph.U.K.

(2)In subsection (1), for “Subsection (2) applies” substitute “ Subsections (2) and (2A) apply ”.

(3)In subsection (1A), for “subsection (2) does not apply” substitute “ subsections (2) and (2A) do not apply ”.

(4)At the beginning of subsection (2) insert “ Except in a case within subsection (2A), ”.

(5)After subsection (2) insert—

(2A)Where the relevant step is within paragraph 1 of Schedule 11 to F(No. 2)A 2017, A's employment income by virtue of section 554Z2(1), or the relevant part of it, is “taxable specific income” in the tax year in which the relevant step is treated as being taken so far as the income is remitted to the United Kingdom in that tax year or in any previous tax year.

(6)In subsection (3) for “this purpose” substitute “ the purposes of subsections (2) and (2A) ”.

(7)In subsection (5)—

(a)in the words before paragraph (a), for “subsection (2)” substitute “ subsection (2) or (2A) ”;

(b)in the words after paragraph (d)—

(i)for “subsection (2)” substitute “ subsection (2) or (2A) ”;

(ii)for “that subsection” substitute “ subsection (2) or (2A) (as the case may be) ”.

41(1)Section 554Z10 (remittance basis: A meets section 26A requirement) is amended in accordance with this paragraph.U.K.

(2)In subsection (1) for “Subsection (2) applies” substitute “ Subsections (2) and (2A) apply ”.

(3)At the beginning of subsection (2) insert “ Except in a case within subsection (2AA), ”.

(4)After subsection (2) insert—

(2AA)Where the relevant step is within paragraph 1 of Schedule 11 to F(No. 2)A 2017, the overseas portion of (as the case may be)—

(a)A's employment income by virtue of section 554Z2(1), or

(b)the relevant part of A's employment income by virtue of that section,

is “taxable specific income” in the tax year in which the relevant step is treated as being taken so far as the overseas portion is remitted to the United Kingdom in that tax year or in any previous tax year.

42(1)Section 554Z11 (remittance basis: supplementary) is amended in accordance with this paragraph.U.K.

(2)In subsection (4), for “554Z9(2) or 554Z10(2)” substitute “ 554Z9(2) or (2A) or 554Z10(2) or (2AA) ”.

(3)In subsection (5), for “554Z9(2) or 554Z10(2)” substitute “ 554Z9(2) or (2A) or 554Z10(2) or (2AA) ”.

(4)In subsection (6), for “554Z9(2) or 554Z10(2)” substitute “ 554Z9(2) or (2A) or 554Z10(2) or (2AA) ”.

43(1)Section 554Z11A (temporary non-residents) is amended in accordance with this paragraph.U.K.

(2)In subsection (2)—

(a)after “554Z9(2)” insert “ or (2A) ”;

(b)after “554Z10(2)” insert “ or (2AA) ”.

(3)In subsection (3)(d)(i), for “554Z9(2) or 554Z10(2)” substitute “ 554Z9(2) or (2A) or 554Z10(2) or (2AA) ”.