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HMRC internal manual

Employment Status Manual

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HM Revenue & Customs
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Salaried member: Anti-Avoidance

ITTOIA S863G

The anti-avoidance legislation is intended to prevent people using artificial structures or arrangements to place members outside the scope of the Salaried Member provisions.

It is important to note that it is not avoidance if the terms under which an individual is a member change and that under the new terms they are a member on terms that are genuinely comparable to those of a partner in a traditional partnership.

There is an overview with links to more detailed guidance at ESM64005.

This chapter contains the following guidance:

 

ESM64005 Salaried Members: Anti Avoidance – Overview
   
ESM64010 Salaried Members: Anti Avoidance – Becoming a member
ESM64015 Salaried Members: Anti Avoidance – Financing arrangements
ESM64040 Salaried Members: Anti Avoidance – Short term appointments
ESM64045 Salaried Members: Anti Avoidance – Use of intermediaries
ESM64050 Salaried Members: Anti Avoidance – Interaction with mixed membership legislation