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HMRC internal manual

Employment Income Manual

HM Revenue & Customs
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Employment income: work-related training: meaning of

Section 251(2) ITEPA 2003

In order to qualify for exemption under Section 250 ITEPA 2003 (see EIM01210), the training must relate to the employee’s current employment or to a “related employment”.

A related employment is another employment with the same employer, or a person connected with the employer, which the employee:

  • is to hold, or
  • has a serious opportunity of holding, or
  • can realistically expect to have a serious opportunity of holding in due course.

The intention is to include all genuine training, in a range of competencies, which the employee would need to advance his/her career or to achieve a career move with his/her employer. For example, language training in preparation for a possible (but not agreed) move to an overseas branch would be included, but training in leisure type activities is not included unless, exceptionally, that activity has a genuine connection with work duties.

The definition of “connected person” in Section 839 ICTA 1988 applies (seeCG14580 onwards).