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HMRC internal manual

Employment Income Manual

Paras 31 and 32: loan charge relevant step: exclusion: cases involving employment related securities

Schedule 11 F(No 2)A 2017

Para 31 provides an exclusion from the 2019 loan charge where P is treated as taking a relevant step by reason of the payment of a sum of money by way of a loan but the provisions of section 554N(13)(b) to (d) apply in relation to employment related securities – see EIM45335.

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