Commencement

Subject to two principal anti-forestalling provisions, the disguised remuneration provisions apply where the relevant step (¶412-330) took place on or after 6 April 2011 (FA 2011, Sch. 2, para. 52).

Anti-forestalling

Anti-forestalling provisions were introduced in order to catch certain transactions that took place after publication of the Finance Bill in December 2010 but before 6 April 2011 that were designed to circumvent the disguised remuneration rules. These apply to a relevant step taken on or after 9 December 2010 but before 6 April 2011 (the ‘early step’).