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HMRC internal manual

Employment Income Manual

HM Revenue & Customs
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Removal or transfer costs: relocation companies: guaranteed sale price schemes: transfer of beneficial interest

Part 4 Chapter 7 ITEPA 2003

The examples of guaranteed sale price schemes (see EIM03133 to EIM03137) make it clear that the transfer of the beneficial interest in the employee’s property is an important step. This is because the tax consequences may be different where the employer incurs expense after the transfer.

The time when beneficial interest passes is not always clear. In a straightforward case of purchase and sale of land the beneficial interest passes to the purchaser:

  • in England and Wales on completion of the contract
  • in Scotland on delivery of the disposition.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)