Section 554P ITEPA 2003

If the subject of a relevant step enjoys an employment income exemption, the relevant step does not give rise to Part 7A income.

If part of the subject of the relevant step falls outside the employment income exemption, you make a just and reasonable apportionment.

‘Employment income exemption’ here means:

an employment income exemption under Part 4 ITEPA 2003 – that is, an exemption from income tax which prevents liability to tax arising in respect of employment income of any kind at all (see EIM20030), or

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