Commentary

I3.157 Exclusions to dispositions for IHT―waiver of remuneration

IHT, trusts and estates

I3.157 Exclusions to dispositions for IHT―waiver of remuneration

I3.157 Exclusions to dispositions for IHT―waiver of remuneration

A waiver or repayment of remuneration is not a transfer of value if two conditions are fulfilled. These are1:

  1.  

    (a)     that the remuneration would be earnings, or would be treated as earnings and would constitute employment income if it were not waived or repaid, and

  2.  

    (b)     that the remuneration would, if not waived or repaid, be deductible from the profits or gains of the employer for income or corporation tax purposes but is not deducted by reason of the waiver or repayment

There is no time limit on the waiver or repayment2.

Employment

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial