Commentary

A7.224 Employment income provided through third parties

Administration and compliance

A7.224 Employment income provided through third parties

A7.224 Employment income provided through third parties

This hallmark applies with effect from 4 November 20131, and was introduced to put beyond doubt whether it is necessary to disclose schemes intended to circumvent the 'disguised remuneration' rules in ITEPA 2003, ss 554A–554Z21 (Pt 7A). Those general anti-avoidance rules were introduced with effect from 6 April 2011 in relation to awards made available after that day, and apply to schemes and arrangements whereby benefits are supplied to an employee by a third party such as trusts, sub-trusts and other intermediaries and there is avoidance of income tax and NIC. Typically an employee benefit trust (EBT) or an unfunded employer financed retirement benefit scheme (EFRBS) might be involved. The rules are complex and have been

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