Part 2 Close Companies

Part 2 Close Companies

Application of Chapter 2 of Part 7A to ITEPA 2003

2

In Part 7A of ITEPA 2003 (employment income provided through third parties), after section 554A (application of Chapter 2) insert—

“Application: close companies

554AA Application of Chapter 2: close companies

(1)     Chapter 2 applies if—

(a)     there is an arrangement (“the relevant arrangementâ€) to which an individual (“Aâ€) is a party or which otherwise (wholly or partly) covers or relates to A,

(b)     it is reasonable to suppose that, in essence—

(i)     the relevant arrangement, or

(ii)     the relevant arrangement so far as it covers or relates to A,

is (wholly or partly) a means of providing, or is otherwise concerned (wholly or partly) with the provision of, A-linked payments or benefits or loans,

(c)     a close company (“Bâ€) enters into a relevant transaction (see section 554AB),

(d)     it is reasonable to suppose that, in essence—

(i)     the relevant transaction is entered into (wholly or partly) in pursuance of the relevant arrangement, or

(ii)     there is some other connection (direct or indirect) between the relevant transaction and the relevant arrangement,

(e)     at the time B enters into the relevant

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