Where income is employment income under ITEPA 2003, Part 7A, Ch. 2 (the disguised remuneration provisions, see ¶412-320ff), the provision in ITEPA 2003, s. 695A (see ¶496-400) takes priority over the provision in s. 696 (ITEPA 2003, s. 696(3)).

Whilst on the face of it, it might appear that s. 695A rather than s. 696 should often be the applicable provision, it should be borne in mind that:

(a)For Part 7A to apply necessarily requires, inter alia, the involvement of a third party (not being the employer company), in relation to the provision or prospective provision of the reward or benefit to the employee (see s. 554A(1));

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