Income Tax (Earnings and Pensions) Act 2003 section 554Z12

Relevant step taken after A's death etc.

Section 554Z12 determines who is liable for income tax when a relevant step (such as a payment, asset transfer or making an asset available) is taken after the death of the employee (referred to as "A") through a third-party arrangement.

• Where A is the person who benefits from the relevant step, A's personal representatives become liable for the income tax on the employment income arising or remitted
• Where the beneficiary is another individual, the employment income or remitted amount is treated as that individual's own employment income for the relevant tax year
• Where the beneficiary is not an individual (for example, a company or trust), the "relevant taxable person" — determined by a priority ordering of UK resident step-takers, the employer (B), or non-UK resident step-takers — is chargeable to income tax at the rate applicable under section 394
• Where there are multiple beneficiaries, the taxable amount must be apportioned between them on a just and reasonable basis