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HMRC internal manual

Employment Income Manual

Paras 27 and 28: loan charge relevant step: exclusion: transfer of employment related loans

Schedule 11 F(No 2)A 2017

Para 27 provides an exclusion from the 2019 loan charge where P would be treated as making a quasi-loan but the provisions of section 554OA(1)(a) to (e) apply in relation to the transfer of employment related loans – see EIM46115.

The exclusion does not apply if there is a connection between the acquisition of the right by the new employer and a tax avoidance arrangement.