Joint Committee on Tax Law Rewrite Bills Minutes of Evidence


The Treatment of Benefits in Kind

  41.  Before 1948 benefits in kind were only taxable if they fell within the definition of "emoluments", as interpreted by case law to mean money or money's worth.

  42.  Finance Act 1948 saw the first charge based on the cost of other provided benefits and since then there have been various piecemeal additions to the body of tax legislation to bring various types of benefit within the charge to tax.

  43.  All of the charging provisions for the various benefits work by treating an amount as if it were an emolument. Various forms of words are used to achieve this:

    —  "treated as an emolument and accordingly chargeable to income tax under Schedule E"—Chapter 2 of Part 5 of ICTA;

    —  "treated as having received an emolument"—sections 141 and 142 of ICTA; and

    —  "treated for the purposes of Schedule E as being in receipt of an emolument"—sections 145 and 146 of ICTA.

  44.  Many, but not all, of the charging provisions are contained in Chapter 2 of Part 5 of ICTA, which applies to directors and employees earning £8,500 a year or more. The other charging provisions apply to all employees, irrespective of rate of earnings.

  45.  As there are now only a minority of employees earning less than £8,500 a year, it seemed sensible to draw together all the provisions charging benefits to tax into a coherent code. A short chapter at the end of that code excludes employees who are lower paid (those earning less than £8,500 a year) who are not directors from those provisions deriving from Chapter 2 of Part 5 of ICTA.

  46.  Appendix 4 to this Memorandum shows how the previous scattering of provisions has been reorganised into a structured Benefits Code in this Bill.

BEFORE AND AFTER EXAMPLES

  47.  Appendix 5 to this Memorandum contains examples of the way in which various provisions look "before and after" the rewrite.

  48.  The first two examples, looking at the rewrite of sections 166 and 199 of ICTA, demonstrate how the rewrite has tackled long sentences containing densely packed concepts.

  49.  The third example is the rewrite of section 195 of ICTA. This shows how one lengthy section with 13 subsections has been divided into three sections, each with fewer subsections; and the position of the employee is now dealt with separately from that of the employee's spouse and children (in clauses 373 and 374 respectively). As a result of the restructuring of the deductions provisions in Part 5 of the Bill, section 195(11) needs no direct successor, and the proposition in section 195(12) has been brought within the wider ambit of clause 330(1).

  50.  The fourth example shows how material from various sections in ICTA has been drawn together to form clause 125 in the Bill.
Change in actual effect on taxpayers
Change NoDescription More tax?Less tax? Timing1[1]Admin2[2]
Changes incorporating extra-statutory concessions or published Statements of Practice or similar
Change 4Taxable earnings: exception from tax on general earnings from overseas Crown employment subject to United Kingdom tax: clause 28 --- -
Change 19Taxable benefits: non-cash vouchers: reduction for meal vouchers: clause 89 --- -
Change 22Taxable benefits: living accommodation: cash equivalent where accommodation provided to more than one employee: clause 108 --- -
Change 27Taxable benefits: cars and car fuel: concession where car available to family members or car is shared: clauses 148, 153 and 169 -
- -
Change 29Taxable benefits: loans: exception for advances for necessary expenses: clauses 179 and 716(2)(a) --- -
Change 47Exemptions: travelling and subsistence during public transport strikes: clauses 245, 266 and 267 --- -
Change 48Exemptions: transport between work and home for disabled employees: clauses 246, 247, 266 and 267 --- -
Change 49Exemptions: transport home, late night working and failure of car-sharing arrangements: clauses 248, 266 and 267 --- -
Change 56Exemptions: annual parties and functions: clauses 264, 266 and 716(2)(c) --- -
Change 58Exemptions: non-cash vouchers for free or subsidised meals: clause 266 --- -
Change 59Exemptions: small gifts from third parties: clauses 270, 324 and 716(2)(g) --- -
Change 67Exemptions: daily subsistence allowances paid to experts seconded to the European Commission: clause 304 --- -
Change 68Exemptions: offshore oil and gas workers: mainland transfers: clause 305 --- -
Change 69Exemptions: miners' and former miners' coal and allowances in lieu of coal: clauses 306 and 646 --- -
Change 70Exemptions: death or retirement benefits provision: clause 307 --- -
Change 77Exemptions: free or subsidised meals: clause 317 --- -
Change 78Exemptions: suggestion awards: clauses 321, 322 and 716(2)(e) --- -
Change 79Exemptions: long service awards: clauses 323 and 716(2)(f) --- -
Change 80Exemptions: expenses incidental to a transfer of a kind not normally met by the transferor: clause 326 --- -
Change 84Deduction for professional membership fees: meaning of "professional fee": clause 343(2) -
- -
Change 100Fixed sum deductions for repairing and maintaining work equipment: clause 367 --- -
Change 108Payments and benefits on termination of employment etc.: exception for contributions to tax-exempt pension schemes: clause 408 --- -
Change 121Share-related income: share options: exception where share option exercised, assigned or released by certain people after the death of the person to whom it was granted: clause 477(4) -
- -
Change 141Pension income: exemptions: wounds and disability pensions: clause 641(1) --- -
Change 142Pension income: exemptions: disablement pensions: clause 644 --- -
Change 146Social security income: foreign benefits: exemptions: clause 681 --- -
Change 173Share-related income: SAYE option schemes and CSOP schemes: jointly owned companies: paragraph 46 of Schedule 3 and paragraph 34 of Schedule 4 --- -
Changes making the legislation shorter, simpler, clearer, more certain or more consistent with other legislation
Change 1Taxable earnings: time when general earnings are received: clauses 18 and 31 --
-
Change 2Taxable earnings: time when non-money earnings are received: clauses 19 and 32 --- -
Change 5Taxable earnings: relief for delayed remittances: remittances in respect of which a claim may be made and conditions for granting relief: clause 35(1) and (2) -
- -
Change 7Taxable earnings: election in respect of delayed remittances: election regarding allocation of income to earlier tax years: clause 36 --- -
Change 9Appeal against Board's decision on domicile or ordinary residence: introduction of a straightforward appeal procedure: clause 43(1) --- -
Change 16Taxable benefits: dispensations: changes in procedure to reflect existing practice: clauses 65 and 96 --- -


Change 26 Taxable benefits: cars: reduction of cash equivalent where car capable of running on road fuel gas: clause 146(2) - - -
Change 28 Replacement of references to 365 days with references to the number of days in the year in order to cover leap years: clauses 152(4), 158(3), 163(1) and 183(3)
- -
Change 32 Taxable benefits: loans: extension of time limit for giving notice of the application of the alternative method of calculating interest: clause 183(2) - - - -
Change 40 Taxable benefits: residual liability to charge: scholarships: cost of benefit: clause 214 - - - -
Change 41 Exemption of modest private use of heavy goods vehicles: widening of exemption: clause 238(1) - - - -
Change 42 Exemption of expenses payments connected with taxable cars and vans and heavy goods vehicles: widening of exemption: clause 239(2) - - - -
Change 44 Exemptions: incidental overnight expenses: deductibility of expenses: clause 240 - - - -
Change 45 Exemptions: works transport services: widening of exemption: clause 242(1) - - - -
Change 46 Exemptions: support for public bus services: widening of exemption: clause 243(1) - - - -
Change 50 Exemptions: transport, travel and subsistence: definition of qualifying journey: clause 249 -
- -
Change 51 Exemptions: work-related training: widening of exemption: clause 250(1) - - - -
Change 52 Exemptions: work-related training and contributions to individual learning account training provided by third parties: clauses 250(1) and 255(1) - - - -
Change 53 Exemptions: work-related training and individual learning account training: incidental expenses: clauses 250(2)(a) and 255(3)(a) - - - -
Change 54 Exemptions: work-related training and individual learning account training: travelling and subsistence expenses: clauses 252(3) and 257(3) -
- -
Change 55 Exemptions: contributions to individual learning account training: widening of exemption: clause 255(1) - - - -
Change 57 Exemptions: third party entertainment: widening of exemption: clause 265(1) - - - -
Change 61 Exemption of removal benefits: benefits and expenses relating to loans on disposal of residences: clauses 279(5) and 284(2)(b) - - - -
Change 65 Exemption of removal benefits: replacement of domestic goods: deduction of sale proceeds: clause 285 -
- -
Change 71 Exemptions: counselling and other outplacement services and retraining courses: clauses 310 and 311 and Part 1 of Schedule 6 - - - -
Change 72 Exemptions: counselling and other outplacement services and retraining courses: clauses 310 and 311 and Part 1 of Schedule 6 - - - -
Change 73 Exemptions: counselling and other outplacement services and retraining courses: deductibility of travel expenses: clauses 310 and 311 -
- -
Change 74 Exemptions: retraining courses: undertaking courses with a view to retraining: clause 311 and Part 1 of Schedule 6 - - - -
Change 81 Deductions for employee's expenses: requirement for payment out of the emoluments of the employment: clause 329 and Chapters 2 to 6 of Part 5 generally - - - -
Change 82 Fixed sum deductions: prevention of double deductions: clauses 330 and 367 - - - -
Change 83 Deductions for employee's expenses: deductions operating through section 198(1) of ICTA: clauses 340 to 342 - - - -
Change 85 Deduction for professional membership fees: new power for Board to extend "professional fee": clauses 343(3) and (4) and 717 - - -
Change 86 Deduction for annual subscriptions: approval of bodies for purpose of receiving subscriptions: notice of decision by Inland Revenue: clause 344(4) - - - -
Change 88 Decisions of the Inland Revenue in relation to approval of bodies: clause 345(1) - - -
Change 89 Decisions of the Inland Revenue in relation to approval of bodies: appeals to the Special Commissioners: clause 345(2) - - -
Change 90 Deduction of expenses of ministers of religion: clause 351 and paragraph 47 of Schedule 6
- - -
Change 91 Deduction of expenses of ministers of religion: determination of deduction for rent by inspectors: clause 351(2) - - -
Change 92 Deductions: agency fees paid by entertainers: application of limit of 17.5% of earnings: clause 352 -
- -


Change 93 Deductions for corresponding payments by non-domiciled employees with foreign employers: clause 355 - - -
Change 97 Deductions: disallowance of certain accommodation expenses of MPs and other representatives: clause 360 - - - -
Change 98 Deductions from benefits code emoluments: limit on amount of deductions: clauses 362 to 365 - - - -
Change 99 Deductions from benefits code emoluments: references to deductibility under specific provisions: clauses 362 to 365 - - - -
Change 101 Deductions for emoluments representing benefits or reimbursed expenses: clause 369 and Chapter 5 of Part 5 generally -
- -
Change 102 Deductions for travel benefits and expenses of non-domiciled employees where duties performed in UK: 5 year limit: clauses 373(3) and 374(3) - - - -
Change 103 Deductions from seafarers' earnings: taking account of other deductions: clause 381 - - - -
Change 106 Benefits from non-approved pension schemes: certain lump sums: reduction of amount which counts as employment income: clause 397 - - - -
Change 110 Payments and benefits on termination of employment etc: valuation of benefits: application of benefits code rules: clause 415 -
- -
Change 111 Share-related income: extending the time limits for the supply of particulars: clauses 432(3), 433(3), 445(3) and 466(3) - - -
Change 112 Share-related income: convertible shares: amount of charge: "event" to include the expiry of a period: clause 439(7) - - - -
Change 119 Share-related income: share options: value of longer-term option for purposes of liability to tax in respect of receipt: clause 475(2) - - - -
Change 124 Share-related income: share options: requiring an apportionment of consideration to be reasonable as well as just: clause 484(2) - - - -
Change 130 Share-related income: the EMI code: disqualifying events relating to employee: clause 535 -
- -
Change 132 Share-related exemptions: priority share allocations: definitions of "director" and "shares": clause 548 - - - -
Change 136 Marine pilots' benefit fund: unauthorised payments: clause 587 - - - -
Change 138 Other employment-related annuities: income chargeable: foreign annuities: clause 613 - - - -
Change 139 Pension income: return of surplus employee additional voluntary contributions: clause 623 - - - -
Change 140 Pension income: exemption for certain lump sums: clause 637 - - - -
Change 144 United Kingdom social security income: exemptions: income support: taxable maximum: basis of calculation: clause 668 -
- -
Change 145 Social security income: foreign benefits: introduction of charge to tax: clause 678 - - - -
Change 147 PAYE: power to make different provision for different cases or classes of case and incidental, consequential, supplementary and transitional provision: clause 684(2) - - - -
Change 150 PAYE: inclusion in the Bill of provision relating to organised arrangements for sharing tips made by subordinate legislation: clause 692 - - - -
Change 154 Donations to charity: payroll deduction scheme: operation of deduction from payments of PAYE income: clause 713(3), (4), and (5); Schedule 6, paragraphs 72 and 73 - - - -
Change 155 Donations to charity: payroll deduction scheme: meaning of "approved agent": clause 714(2) - - - -
Change 156 Donations to charity: approval of payroll deduction schemes: regulation by the Treasury: clause 715(3) - - - -
Change 158 References to "the Inland Revenue": clause 720 - - - -
Change 159 Definition of "personal representatives" and replacement of the expression "executors or administrators" with "personal representatives": clause 721 - - - -
Change 163 Share-related income: share incentive plans: duration of accumulation periods: paragraph 51 of Schedule 2 - - - -
Change 164 Share-related income: share incentive plans: approval procedure: paragraph 81 of Schedule 2 - - - -
Change 165 Share-related income: share incentive plans: effect of plan termination notice: paragraph 90 of Schedule 2 - - - -


Change 166 Share-related income: SAYE option schemes: all-employee nature of schemes: paragraph 6 of Schedule 3 - - - -
Change 167 Share-related income: SAYE option schemes and CSOP schemes: disregarding of interests in SIPs: paragraph 13 of Schedule 3 and paragraph 11 of Schedule 4 -
- -
Change 168 Share-related income: SAYE option schemes and CSOP schemes: restrictions to which scheme shares may be subject: paragraph 21 of Schedule 3 and paragraph 19 of Schedule 4 - - - -
Change 170 Share-related income: SAYE option schemes and CSOP schemes: notice to be given by Inland Revenue of decision to grant, refuse or withdraw approval of scheme etc: paragraphs 40, 42 and 43 of Schedule 3 and paragraphs 28, 30 and 31 of Schedule 4 - - - -
Change 171 Share-related income: SAYE option schemes and CSOP schemes: appeals against decisions by Inland Revenue to grant, refuse or withdraw approval of schemes: paragraphs 41 and 44 of Schedule 3 and paragraphs 29 and 32 of Schedule 4 - - - -
Change 172 Share-related income: SAYE option schemes and CSOP schemes: information to be given to Inland Revenue: paragraph 45 of Schedule 3 and paragraph 33 of Schedule 4 - - -
Change 176 Share-related income: the EMI code: "eligible employees": paragraph 26 of Schedule 5 - ; - -
Change 178 Share-related income: the EMI code: notices following notification of option: paragraphs 45 and 46 of Schedule 5 - - - -
Change 179 Share-related income: the EMI code: information to be given to Inland Revenue: paragraph 51 of Schedule 5 - - - -
Change 180 Share-related income: the EMI code: amendment of monetary limits: paragraph 54 of Schedule 5 -
- -
Change 181 Relief from tax on annual payments under certain insurance policies: section 580A(7) of ICTA: paragraph 65 of Schedule 6 - - - -
Change 182 Deductible payments: combined claims: paragraph 217 of Schedule 6 - - -
Changes correcting points overlooked in the course of consolidation Acts, missed consequential amendments to earlier legislation, or other technical defects
Change 6 Taxable earnings: relief for delayed remittances: replacement of references to income "arising" with references to income "received": clause 35(2) and (4) - - - -
Change 23 Taxable benefits: living accommodation and residual liability to charge: calculation of annual values: clauses 110 and 207 - - - -
Change 24 Taxable benefits: living accommodation and residual liability to charge: meaning of "all usual tenant's rates and taxes": clauses 110 and 207 - - - -
Change 75 Exemptions: living accommodation: exemption where rates etc. discharged for employee: clause 314 - - - -
Change 95 Deduction of business entertainment and gifts expenses: exception where employer's expenses disallowed: tonnage tax companies: clause 357(4) - - - -
Change 109 Payments and benefits on termination of employment etc: reduction in cases of foreign service: clause 414 - - - -
Change 113 Share-related income: post-acquisition benefits from shares: amount of charge where increase in value of shares of dependent subsidiaries: clause 455 - - - -
Change 114 Shares: post-acquisition benefits from shares: deemed acquisitions by director or employee: clauses 457 and 463 - - - -
Change 115 Share-related income: post-acquisition benefits from shares: restriction of liability to tax on special benefits from shares: clause 460 - - - -
Change 117 Share-related income: post-acquisition benefits from shares: meaning of "interest in shares": clause 470 - - - -
Change 125 Share-related income: share options: correcting consolidation error in section 136(2)(b) of ICTA: clause 485(5)(b) and corresponding provisions - - - -
Change 161 Share-related income: share incentive plans: information to be given about performance targets and measures: paragraph 40 of Schedule 2 - - - -
Change 162 Share-related income: share incentive plans: authorisation of deductions from salary under partnership share agreements: paragraph 44 of Schedule 2 - - - -


Change 175 Share-related income: the EMI code: "qualifying trade" (leasing of ships): paragraph 18 of Schedule 5 -
- -
Change 177 Share-related income: the EMI code: further requirements to be met as to replacement option: paragraphs 41 and 43 of Schedule 5 - - - -
Change 183 PAYE: paragraph 10 of Schedule 2 to the Tax Credits Act 1999: paragraph 241 of Schedule 6 - - - -
Changes removing an anomaly which is patently unfair
Change 3 Taxable earnings: deductions to be made in calculating "chargeable overseas earnings": clauses 23 and 24 -
- -
Change 12 Intermediaries: widening of the category of associated companies to which paragraph 3(2) of Schedule 12 to FA 2000 applies: clause 51(2) -
- -
Change 15 Taxable benefits: relationship between earnings and benefits code: clause 64 - - - -
Change 18 Taxable benefits: vouchers and credit-tokens: exceptions where voucher or token provided for personal reasons or is of a kind made available to the public generally: clauses 73(2), 78, 82(2), 85, 90(2) and 93 - - - -
Change 20 Taxable benefits: vouchers and credit-tokens: extension of disregard for money, goods or services obtained: clause 95 - - - -
Change 21 Taxable benefits: living accommodation: special rule for calculating cost of providing accommodation: clause 107 -
- -
Change 25 Taxable benefits: cars: modification of provisions where car temporarily replaced: clause 145(2) - - - -
Change 30 Taxable benefits: loans: exception for loans totalling not more than £5,000: clause 180 - - - -
Change 34 Taxable benefits: loans: prevention of double charge under section 421 of ICTA where loan released or written off: clause 189(1)(b) - - - -
Change 35 Taxable benefits: loans: relief where released or written off loan is subsequently repaid: clause 191(3) -
- -
Change 36 Taxable benefits: notional loans in respect of acquisitions of shares: taking account of advance payments for shares: clauses 193(1)(a) and (b) and 194(2)(a) - - - -
Change 37 Taxable benefits: notional loans in respect of acquisitions of shares: listing the provisions of Chapter 7 of Part 3 which apply to notional loans: clause193(4) - - - -
Change 38 Taxable benefits: notional loans in respect of acquisitions of shares: relationship with liability to tax in respect of exercise of share option: clauses 194(2)(c) and 196 - - - -
Change 39 Taxable benefits: residual liability to charge: scholarships provided under arrangements entered into by the employer or a connected person if the employer is an individual: clause 212 - - - -
Change 43 Exemption where payments and benefits provided to the lower paid in connection with heavy goods vehicles: clauses 239(8) and 269(4)(b) -
- -
Change 60 Exemption of removal benefits and expenses: vouchers and credit-tokens: clauses 272 and 287 -
- -
Change 63 Exemption of removal benefits: exclusion where car and van benefits otherwise taxable: clause 283 - - - -
Change 66 Exemption of removal benefits and expenses: limit on exemption: clause 287 -
- -
Change 76 Exemptions: living accommodation: limit on charge to tax on connected expenses: clause 315 -
- -
Change 94 Deduction of business entertainment and gifts expenses: restriction of disallowance to expenses connected with employer's trade: clause 356(1) - - - -
Change 96 Deduction of business gifts expenses: exception for advertisements of the donor: other companies in employer's group: clauses 358(3) and (4) and 716(2)(h) -
- -
Change 104 Payments to non-approved pension schemes: relief where no benefits paid or payable: clauses 386(6) and 392(1) and (3) - - - -
Change 105 Payments to non-approved pension schemes: exception for seafarers with overseas earnings: clause 391 - - - -
Change 118 Share-related income: share options: application of rule about the employment by reason of which a share option was granted to the charge in clause 477: clause 473(1) - - - -
Change 123 Share-related income: share options: deductions for the amount of the liability to tax in respect of the receipt of the share option: clause 478(2) and (3) - - - -
Change 151 PAYE (gains from share options): limit on the amount of the consideration that is to be treated as a payment of PAYE income: clause 700 - - - -

Change 160 Share related income: share incentive plans: restriction on participating in both share incentive plan and approved profit sharing scheme in a tax year: paragraph 18 of Schedule 2 -
- -
Changes making clear the intended and accepted interpretation of legislation that is currently somewhat opaque
Change 10 Application of provisions to agency workers: treatment of services under agency contract: clause 44(2) - - - -
Change 11 Application of provisions to agency workers: arrangements with agencies: clause 45 - - - -
Change 17 Taxable benefits: expenses payments: clause 70 - - - -
Change 87 Deduction for annual subscriptions: approval of bodies for purpose of receiving subscriptions: timing of deduction: clause 344(7) - - - -
Change 107 Payments and benefits on termination of employment etc: meaning of benefit: clause 402(4) - - - -
Change 116 Share-related income: post-acquisition benefits from shares: duty to provide information: clause 465 - - - -
Change 120 Share-related income: share options: value of longer-term option to acquire convertible shares: clause 475(2) - - - -
Change 122 Share-related income: share options: amount of charge to tax under Case VI of Schedule D: clause 477(6) - - - -
Change 126 Share-related income: share incentive plans : no charge on increase in value of shares of dependent subsidiary: clause 495 - - - -
Change 128 Share-related income: share incentive plans: identification of shares ceasing to be subject to plan: clause 508 - - - -
Change 129 Share-related income: SAYE option schemes and CSOP schemes: no charge in respect of exercise of options: clauses 519 and 524 - - - -
Change 131 Share-related income: the EMI code: no charge on acquisition of shares as a taxable benefit: clause 540 -
- -
Change 134 Former employees: deductions for liabilities: start of period during which payment must be made to be deductible from total income: clause 556(1) - - -
Change 143 United Kingdom social security income: incapacity benefit taxable: clause 660 - - - -
Change 148 PAYE: directions as to income of non-resident or not ordinarily resident employees to apply only to income paid by or on behalf of the employer: clause 690 - - - -
Change 149 PAYE: scope of power to give directions as to income of non-resident or not ordinarily resident employees and applications for such directions: clause 690 - - - -
Change 152 PAYE (gains from share options): cases where the consideration for an assignment or release of a share option is a readily convertible asset in the form of a voucher or credit-token: clause 700 - - - -
Changes filling a gap in the legislation
Change 8 Board to determine disputes as to domicile or ordinary residence: widening of the availability of the procedure: clause 42(3) - - -
Change 13 Intermediaries: treating all relevant engagements as the duties of a continuous employment: clause 54(6) - - - -
Change 14 Intermediaries: normal timing rules to apply for determining when a non-cash benefit is to be treated as received: clause 55(5) - - - -
Change 31 Taxable benefits: loans: method of calculating the amount of interest payable at the official rate: clauses 182 and 183(1) - - -
Change 33 Taxable benefits: loans: method of calculating the cash equivalent of the benefit of a loan which is replaced: clause 186(3) - - - -
Change 62 Exemption of removal benefits: travelling and subsistence costs of relevant children where employee in temporary accommodation: clause 281 -
- -
Change 64 Exemption of removal benefits: bridging loan expenses: interest partially exempt: clause 284(4) and (5) - - - -
Change 127 Share-related income: share incentive plans: no charge in respect of incidental expenditure: clause 499 -
- -
Change 133 Share-related income: employee benefit trusts: "qualifying disposals": clause 551 - - - -
Change 135 Pension income and social security income: person chargeable: clauses 572, 579, 582, 592, 597, 600, 618, 622, 636 and 662 - - - -
Change 137 Approved personal pension schemes: annuities: income chargeable: clause 596 - - - -
Change 153 PAYE: tax accounted for under PAYE on a notional payment to be credited to the employee in respect of his liability to income tax: clause 710 - - - -
Change 157 Control: application of the definition in section 840 of ICTA for the purposes of paragraphs 3(2) and (4) and 19(3) of Schedule 12 to FA 2000: clause 719 - - - -
Change 169 Share-related income: SAYE option schemes and CSOP schemes: price for acquisition of shares: paragraph 28 of Schedule 3 and paragraph 22 of Schedule 4 - - - -
Change 174 Share-related income: the EMI code: meaning of "qualifying subsidiary": paragraph 11 of Schedule 5 -
- -

1[1] Affects the time when income is taken into account for tax purposes

2[2] Affects only administrative procedures relating to tax


 
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