11.6.1 Background to the rules

Assets held within any employee trust are potentially subject to the rules on disguised remuneration, which can be found in ITEPA 2003, Pt. 7A.

The disguised remuneration rules apply where an arrangement meets the gateway requirements set out in ITEPA 2003, s. 554A:

‘(a)a person (“A”) is an employee, or former or prospective employee, of another person (“B”),

(b)there is an arrangement (“the relevant arrangement”) to which A is a party or which otherwise (wholly or partly) covers or relates to A,

(c)It is reasonable to suppose that, in essence–

(i)the relevant arrangement, or

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