264. Disguised remuneration: employment income provided through third parties.

Detailed and complicated anti-avoidance legislation targets disguised remuneration arrangements using third parties, for example, employee benefits trusts (EBTs)¹. The legislation aims to tax the disguised remuneration as employment income². In general terms, these rules apply where:

1.  

   (1)     a person ('A') is an employee, or a former or prospective employee, of another person 'B');

2.  

   (2)     there is an arrangement ('the relevant arrangement') to which A is a party or which otherwise (wholly or partly) covers or relates to A;

3.  

   (3)     it is reasonable to suppose that, in essence, the relevant arrangement is (wholly or partly) a means of providing, or