Karen Cooper (Cooper Cavendish) sets out the rules, tax treatment and the impact of legislation on EBTs and remuneration planning.
When the rules apply: the gateways
There are two gateways under Income Tax (Earnings and Pensions) Act (ITEPA) 2003 Part 7A:
the ‘main gateway’ which has been in force since the legislation was introduced; and
the ‘close companies gateway’ which was introduced from 6 April 2018.
Where an arrangement passes through a gateway a Part 7A charge arises (see ‘The charge to tax’ below).
The main gateway
The main gateway applies where the following conditions are met:
There is a ‘relevant’ arrangement which relates to an existing former or prospective employee or a relevant person ‘linked’ to the employee. Employee for these purposes includes non-executive directors and office holders. The...
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Karen Cooper (Cooper Cavendish) sets out the rules, tax treatment and the impact of legislation on EBTs and remuneration planning.
When the rules apply: the gateways
There are two gateways under Income Tax (Earnings and Pensions) Act (ITEPA) 2003 Part 7A:
the ‘main gateway’ which has been in force since the legislation was introduced; and
the ‘close companies gateway’ which was introduced from 6 April 2018.
Where an arrangement passes through a gateway a Part 7A charge arises (see ‘The charge to tax’ below).
The main gateway
The main gateway applies where the following conditions are met:
There is a ‘relevant’ arrangement which relates to an existing former or prospective employee or a relevant person ‘linked’ to the employee. Employee for these purposes includes non-executive directors and office holders. The...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
