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HMRC internal manual

Employment Income Manual

Employment income: transfer of real property to employees: alternative charges to tax

Where on a transfer of property at undervalue liability is not established under Section 62 ITEPA 2003 (see EIM08001), it may arise under other legislation:

  • where the taxpayer is a member of the company providing the asset – as Savings and Investment Income (see CT15250 onwards).
  • where the employment concerned is not an excluded employment - under Part 3 Chapter 10 ITEPA 2003 (see EIM21640 onwards)
  • where the transfer is part of an unapproved retirement benefits scheme - under Part 6 Chapter 1 ITEPA 2003 (see EIM15010 onwards)
  • where the transfer is otherwise in connection with the termination of an office or employment - under Part 6 Chapter 3 ITEPA 2003 (see EIM13000 onwards)
  • where, exceptionally, a voucher or credit token is involved - under Part 3 Chapter 4 ITEPA 2003 (see EIM16010 onwards).