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HMRC internal manual

Employment Income Manual

Paras 29 and 30: loan charge relevant step: exclusion: transaction under employee benefit packages

Schedule 11 F(No 2)A 2017

Para 29 provides an exclusion from the 2019 loan charge where P would be treated as making a payment of a sum of money by way of a loan but the provisions of section 554G apply in terms of transactions under employee benefit packages – see EIM45220.

The exclusion does not apply if there is a connection between the relevant step and a tax avoidance arrangement.