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HMRC internal manual

Employment Income Manual

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HM Revenue & Customs
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Employment income provided through third parties: subsequent income tax liability: prevention of double charge

Section 554Z13 ITEPA 2003

Section 554Z13 prevents a further income tax charge applying after Part 7A income has arisen, if the specified conditions are met.

Conditions

There are four conditions. They are bulleted below.

  • An event occurs after the relevant step.
  • But for Section 554Z13, this later event would give rise to a liability to income tax (not necessarily on A) on an amount (‘the later amount’).
  • The liability would arise other than by virtue of:

    • Part 7A Chapter 2 ITEPA 2003 (Part 7A income),
    • Chapters 2 to 5 of Part 7 ITEPA 2003 (employment-related securities), or
    • Part 9 ITEPA 2003 (pension income).
  • To prevent a double charge to income tax in respect of the sum of money or asset which is the subject of the relevant step, it is just and reasonable for Section 554Z13 to apply.

Relief

To the extent that it is just and reasonable in order to prevent this double charge, Section 554Z13 stops the later event giving rise to a liability to income tax on the later amount.