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HMRC internal manual

Employment Income Manual

The benefits code: person providing a benefit

Section 209 ITEPA 2003

For the purposes of Part 3 Chapter 10 and Part 4 ITEPA 2003 the person providing a benefit is deemed to be the person at whose cost the provision is made (Section 209 ITEPA 2003). This may not necessarily be the person who physically ‘hands over’ the benefit to the employee. See Wicks v Firth (56TC338) and EIM21220.