EIM45475 - Employment income provided through third parties: exclusions: earmarking for employee share and share option schemes: meaning of 'relevant income'

Sections 554J(13), 554K(12), 554L(15) and 554M(14) ITEPA 2003

In Sections 554J to 554M, 鈥榬elevant income鈥�, in relation to any earmarked shares, means any income with the following features.

  • The income arises (directly or indirectly) from the shares before the fall-back charge applies.
  • It is the subject of a relevant step within Section 554B taken by the relevant third person under review.
  • This relevant step would give rise to Part 7A income but for Section 554Q (exclusions: income arising from earmarked sum or asset). See EIM45245.
  • At the time of the fall-back charge, this income continues to be held on a Section 554B basis.

On Section 554B, see EIM45095.