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

Interpretation: general

Section 554Z provides the key definitions and interpretive rules that apply throughout Part 7A, which deals with employment income provided through third parties.

• An "arrangement" is defined very broadly to include any agreement, scheme, settlement, transaction, trust or understanding, whether or not legally enforceable
• Group company membership is determined using capital gains tax rules but with a lower 51 per cent ownership threshold instead of the usual 75 per cent
• References to payment of a sum of money specifically include payments made by way of a loan
• A "tax avoidance arrangement" is one where the main purpose (or one of the main purposes) of any party is the avoidance of tax or national insurance contributions, and a step can be connected to such an arrangement even if the person taking the step is unaware of it