Income Tax (Earnings and Pensions) Act 2003 section 554

Attribution of further interest in company

Section 554 deals with how an individual (or their associate) may be treated as owning an additional percentage of a company's ordinary share capital when they have received payments from more than one employee benefit trust connected with the company.

• Where a person already has a deemed ownership percentage under section 552, additional payments from other connected trusts within the previous 12 months can increase that deemed ownership further
• A trust is "connected with" the company if, at any time in the three years before the payment date, its assets included any part of the company's ordinary share capital
• The individual or associate is treated as beneficially owning both the original deemed percentage and the additional percentage calculated from the other trust payments, on top of any shares they actually own
• Where multiple payments have been received from one connected trust, only the last payment within the 12-month period is taken into account for the additional attribution