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HMRC internal manual

Employment Income Manual

PAYE: meaning of readily convertible assets: an asset likely to provide cash without action by the owner

The most common scheme of this type concerned a reversionary interest in an offshore trust (RIOT). The trusts used in these schemes typically had a life expectancy, stated in the trust deed, lasting only a week or so. When the trust ceased the owner of the interest in the trust inevitably received a payment of the capital held in that trust, see example EIM11925.