SCHEDULE 2 Employment Income Provided Through Third Parties

SCHEDULE 2 Employment Income Provided Through Third Parties

Section 26

Main provision

1

After Part 7 of ITEPA 2003 insert—

“Part 7A
Employment Income Provided Through Third Parties
Chapter 1
Application etc
Application
554A Application of Chapter 2

(1)     Chapter 2 applies if—

(a)     a person (“Aâ€) is an employee, or a former or prospective employee, of another person (“Bâ€),

(b)     there is an arrangement (“the relevant arrangementâ€) to which A is a party or which otherwise (wholly or partly) covers or relates to A,

(c)     it is reasonable to suppose that, in essence—

(i)     the relevant arrangement, or

(ii)     the relevant arrangement so far as it covers or relates to A,

is (wholly or partly) a means of providing, or is otherwise concerned (wholly or partly) with the provision of, rewards or recognition or loans in connection with A's employment, or former or prospective employment, with B,

(d)     a relevant step is taken by a relevant third person, and

(e)     it is reasonable to suppose that, in essence—

(i)     the relevant step is taken (wholly or partly) in pursuance of the relevant arrangement, or

(ii)     there is some other connection (direct or indirect) between the relevant step

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