16 Election for loan charge to be split over three tax years

16  Election for loan charge to be split over three tax years

(1)     Schedule 11 to F(No 2)A 2017 (employment income provided through third parties: loans etc outstanding on 5 April 2019) is amended as follows.

(2)     In paragraph 1 (person to be treated as taking a relevant step for the purposes of Part 7A of ITEPA 2003 by reason of making loan or quasi-loan)—

(a)     after sub-paragraph (6) insert—

“(6A)     Sub-paragraph (4) is subject to paragraph 1A(5).”, and

(b)     in sub-paragraph (7)—

(i)     in the words before paragraph (a) after “paragraph” insert “and paragraph 1A”, and

(ii)     in paragraph (a) for “the following provisions of this Schedule” substitute “paragraphs 3 to 18”.

(3)     After paragraph 1 insert—

“1

(1)     This paragraph applies where—

(a)     a person (“P”) is treated as taking a relevant step within paragraph 1 (“the initial step”) by reason of making a loan or quasi-loan, and

(b)     an election has been made by A for the purposes of this paragraph.

(2)     P is treated as taking two further relevant steps for the purposes of Part 7A of ITEPA 2003.

(3)     P is treated as taking one of the further steps on

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