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HMRC internal manual

Employment Income Manual

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HM Revenue & Customs
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Employment income: exemption for long service testimonial awards: meaning of "same employer"

Section 323(5) ITEPA 2003

The exemption in Section 323 ITEPA 2003 applies to awards that are made to mark long service with the same employer (see EIM01500). For the purpose of the exemption, service with two or more employers is treated as being with the same employer if:

  • each of them is a successor or predecessor of the other(s), or
  • one of them is a company that belongs (or has belonged) to the same group as the others (or a predecessor or successor of the others).

“Group” means a body corporate and its 51% subsidiaries.