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HMRC internal manual

Employment Income Manual

Benefits: scholarships provided for members of the family or household of a director or employee: claims that awards are fortuitous

Section 213 ITEPA 2003The award of a scholarship is not within the exemption at

EIM30004 if it can be shown that it was made “by reason of a person’s employment” within the ordinary meaning of that phrase (see 1. of EIM30002).

If it is claimed that a particular scholarship award has been made fortuitously you will need to consider:
* whether the awards scheme is genuinely open to the public at large * the way in which the availability of the awards is publicised * the criteria by which the awards are made * the proportion of awards that are made to members of the families or households of employees.