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| | Schedule 2, page 78, line 20, leave out from beginning to ‘and’ in line 23 and |
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| | | ‘(a) | on its acquisition, sum or asset T— |
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| | | (i) | is the subject of a relevant step within section 554B |
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| | | taken by P by reason of which Chapter 2 applies or |
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| | | would apply apart from subsection (3) above or any of |
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| | | sections 554H to 554LA, 554P or 554S, or |
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| | | (ii) | if sub-paragraph (i) does not apply, is held by or on |
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| | | behalf of P on the same basis as that on which sum or |
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| | | asset S was held by or on behalf of P immediately |
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| | | before the acquisition,’. |
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| | Schedule 2, page 84, line 42, at end insert— |
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| | | ‘(5A) | And for that purpose, section 170(2) to (11) is to be read as if for “75 |
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| | | per cent” (wherever occurring) there were substituted “51 per cent” |
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| | | (with section 1154(2) of CTA 2010 applying accordingly).’ |
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| | Schedule 2, page 88, line 8, after ‘section’ insert ‘or section 554Z6’. |
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| | Schedule 2, page 88, line 9, leave out ‘sections 554Z5 to’ and insert ‘section 554Z5 |
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| | Schedule 2, page 88, line 43, after ‘(10)’ insert ‘or 554LA(4), (6) or (8)’. |
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| | Schedule 2, page 89, line 2, leave out ‘B may grant A a right (“a relevant share |
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| | option”)’ and insert ‘a right (“a relevant share option”) may be granted to A’. |
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| | Schedule 2, page 89, line 36, after ‘554L(10)’ insert ‘or 554LA(8)’. |
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| | Schedule 2, page 90, line 9, leave out ‘which is three months after’ and insert |
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| | ‘falling immediately after the period of three months starting with’. |
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| | Schedule 2, page 90, line 11, after ‘at’ insert ‘the end of’. |
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| | Schedule 2, page 96, line 20, at end insert— |
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| | | ‘(10) | In relation to times after the relief is given, the Tax Acts have effect as |
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| | | if this Chapter had never applied by reason of the original relevant |
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| | Schedule 2, page 111, line 18, leave out from ‘earnings’ to end of line 28 and insert |
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| | ‘of A from A’s employment with B within Chapter 1 of Part 3 of ITEPA 2003 for the pre- |
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| | 6 April 2011 tax year, or |
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| | | (ii) | the tax payable by A for the pre-6 April 2011 tax year was |
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| | | otherwise decided on the basis that the pre-6 April 2011 step |
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| | | was to be treated as giving rise to earnings of A from A’s |
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| | | employment with B within Chapter 1 of Part 3 of ITEPA 2003 |
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| | | |
| | | (e) | before the chargeable step is taken, A or B has paid, or otherwise |
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| | | accounted for, any tax which A or B is required to pay or otherwise |
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| | | account for as a consequence of— |
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| | | (i) | the agreement mentioned in paragraph (d)(i), or |
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| | | (ii) | the tax payable by A for the pre-6 April 2011 tax year having |
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| | | otherwise been decided on the basis mentioned in paragraph |
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| | | (f) | after any reductions under sections 554Z3 to 554Z7 of ITEPA 2003, it |
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| | | is determined on a just and reasonable basis that the value of the |
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| | | chargeable step represents (or still represents after any such |
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| | | reductions) to any extent— |
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| | | (i) | the earnings treated as arising from the pre-6 April 2011 step |
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| | | as mentioned in paragraph (d)(i) or (ii), or |
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| | | (ii) | any return on those earnings since the taking of the pre-6 April |
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| | | 2011 step (whether income or capital, direct or indirect or |
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| | | |
| | | (2) | After any reductions under sections 554Z3 to 554Z7 of ITEPA 2003, the value |
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| | | of the chargeable step is to be reduced (but not below nil) by an amount |
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| | | reflecting the extent to which, as determined under sub-paragraph (1)(f), that |
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| | | value represents (or still represents) the earnings mentioned in sub-paragraph |
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| | | (1)(f)(i) or any return on those earnings mentioned in sub-paragraph (1)(f)(ii). |
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| | | (3) | In sub-paragraph (1)(f)(ii) “return” does not include any return so far as, it is |
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| | | reasonable to suppose, the return exceeds the return which might have been |
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| | | expected applying the assumption that all relevant connected persons are |
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| | | acting at arm’s length of each other. |
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| | | (4) | In sub-paragraph (3) “relevant connected person” means a person with a |
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| | | connection (direct or indirect) to an arrangement (within the meaning of Part |
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| | | 7A of ITEPA 2003) by virtue of which the return arises.’. |
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