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HMRC internal manual

Employment Income Manual

Employment income provided through third parties: exclusions: earmarking for employee share and share option schemes: meaning of 'relevant income'

Sections 554J(13), 554K(12), 554L(15) and 554M(14) ITEPA 2003

In Sections 554J to 554M, ‘relevant income’, in relation to any earmarked shares, means any income with the following features.

  • The income arises (directly or indirectly) from the shares before the fall-back charge applies.
  • It is the subject of a relevant step within Section 554B taken by the relevant third person under review.
  • This relevant step would give rise to Part 7A income but for Section 554Q (exclusions: income arising from earmarked sum or asset). See EIM45245.
  • At the time of the fall-back charge, this income continues to be held on a Section 554B basis.

On Section 554B, see EIM45095.