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HMRC internal manual

Inheritance Tax Manual

Pre-owned assets: avoidance of double charges: charge to employment benefits

It is possible that a chargeable person may be subject to income tax in respect of their occupation of land or use of a chattel both as a pre-owned asset and under the benefits code of ITEPA03/Part 3. In such circumstances, the provisions of Part 3 have priority. There will only be a POA charge on any amount that exceeds the amount treated as earnings under Part 3.