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HMRC internal manual

Employment Income Manual

Tax treatment of benefits matches and testimonials given to sportspersons –The Sporting Testimonial Payments (Excluded Relevant Step) Regulations

The Sporting Testimonial Payments (Excluded Relevant Step) Regulations 2016

Chapter 2 of Part 7A ITEPA provides that where an arrangement exists for providing rewards, recognition or loans in connection with a person’s employment, the value of a payment made by a third party is treated as the person’s employment income.

The Sporting Testimonial Payments regulations provides for the disapplication of Part 7A in relation to sporting testimonial payments, ensuring that such payments are only taxable under section 226E ITEPA 2003, which treats them as earnings (see EIM64121), subject to the limited exemption in section 306B of ITEPA 2003 (see EIM64122).