Income Tax (Earnings and Pensions) Act 2003 section 554C

Relevant steps: payment of sum, transfer of asset etc.

Section 554C defines the types of actions — known as "relevant steps" — that can trigger a tax charge under Part 7A, including payments, asset transfers, loans, security arrangements, and long leases made in favour of an employee or connected person.

  • A relevant step includes paying money, transferring assets, acquiring rights linked to payments or transfers, releasing or writing off loans, and granting leases likely to exceed 21 years to an employee or person connected to them
  • A "relevant person" means the employee, anyone chosen by the employee, or — where the step is taken at the employee's direction — any other person, including persons linked to the employee
  • "Loan" is defined broadly to include any form of credit or any payment purported to be made by way of a loan, and where a debtor acquires the creditor's right, the creditor is treated as having released the loan
  • Making money or assets available as security counts even if done informally, even if the relevant person has no legal right to use it, and even if the security is never actually called upon

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