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 the 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.


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