Employment income: work-related training: meaning of related employment
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 (see CG14580 onwards).