Disguised remuneration tax legislation (Part 7A of ITEPA 2003): issues for share plans and other employee benefits

The disguised remuneration rules in Part 7A of  Income Tax (Earnings and Pensions)  Act 2003 counter tax avoidance using employee benefit trusts and other intermediaries to reward employees or their family members, but are very broadly drafted. This note considers the scope of the legislation, HMRC's guidance about it and how it applies in practice, and highlights some practical difficulties it may cause for normal commercial share and bonus schemes.


The full text of this resource is available by logging in or by requesting a trial. If you have any questions, please contact us or your Practical Law Account Executive.

Free trial

A free trial will give you:

Unlimited access to our online legal know-how services during the trial period
Full training and support
Four issues of Practical Law The Journal, the companion to Practical Law online
Weekly update e-mails on current legal developments in your practice area


Subscribers and trialists can login below

Contact Us

If you need assistance logging in or have any questions about our services, please contact us.

{ "siteName" : "PLC", "objType" : "PLC_Doc_C", "objID" : "1247433815110", "objName" : "Main practice note Part 7A share plans other benefits", "userID" : "2", "objUrl" : "http://us.practicallaw.com/cs/Satellite/us/resource/4-504-5317?null", "pageType" : "Resource", "academicUserID" : "", "contentAccessed" : "false", "analyticsPermCookie" : "27d72e31c:152b8787b55:-5c4d", "analyticsSessionCookie" : "27d72e31c:152b8787b55:-5c4c", "statisticSensorPath" : "http://analytics.practicallaw.com/sensor/statistic" }