Related HMRC Manuals

61W(1)  Subsection (2) applies where–

(a)a person (“the payee”) receives a payment or benefit (“the end-of-line remuneration”) from another person (“the paying intermediary”),

(b)the end-of-line remuneration can reasonably be taken to represent remuneration for services of the payee to a public authority,

(c)a payment (“the deemed payment”) has been treated by section 61N(3) as made to the payee,

(d)the underlying chain payment can reasonably be taken to be for the same services of the payee to that public authority, and

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