Corporation Tax Act 2009 section 140

Unpaid remuneration

Section 140 sets out transitional rules for how amounts held by intermediaries are treated as employees' remuneration for the purposes of the unpaid remuneration provisions, with different rules applying depending on whether the period of account ended before or on or after 27 November 2002.

• The rules apply to the unpaid remuneration provisions under section 1288, and to the equivalent rules for life assurance companies under section 1249(1) to (3) as applied by section 82 of Finance Act 2012.
• For periods of account ending before 27 November 2002, amounts held by an intermediary with a view to becoming employees' remuneration count as remuneration charged in the accounts.
• For periods of account ending on or after 27 November 2002, amounts in respect of employee benefit contributions made before that date and held by an intermediary with a view to becoming employees' remuneration also count as remuneration charged in the accounts.
• The 27 November 2002 date marks the boundary between the older, broader intermediary rule and the narrower rule that applies only to employee benefit contributions made before that date.