Income Tax (Earnings and Pensions) Act 2003 section 554Z13

Subsequent income tax liability

Section 554Z13 prevents a double charge to income tax where a later event gives rise to a tax liability on the same money or asset that was already subject to tax under a relevant step in the disguised remuneration rules.

• Where a relevant step has already been taken and a later event occurs that would normally create an income tax liability for the employee (A) or any other person, this section may apply to prevent double taxation.
• The later event must give rise to an income tax charge other than one arising under the disguised remuneration rules (Chapter 2 of Part 7A), the employment-related securities rules (Chapters 2 to 5 of Part 7), or the pension income rules (Part 9).
• The section only applies where it is just and reasonable to do so, in order to avoid a double charge to income tax on the same sum of money or asset that was the subject of the relevant step.
• To the extent that it is just and reasonable, the income tax liability on the later amount arising from the later event is removed entirely.