Employees
This
adran has no associated
Memorandwm Esboniadol
13.—(1) A person (“P”) is not to be treated as an intermediary in relation to a reportable cross-border arrangement where—
(a)P is an employee of an employer (“E”), and
(b)E is an intermediary or relevant taxpayer in relation to the reportable cross-border arrangement.
(2) In this regulation, “employee” and “employer” have the meanings given by section 4 of the Income Tax (Earnings and Pensions) Act 2003(1) (as read with section 5(2) of that Act).
(3) For the purposes of this regulation, where E is connected to another person (“F”), P is to be treated as an employee of F as well as being an employee of E.
(4) In this regulation, E is connected with F where E is closely bound to F by financial, economic or organisational links.
(1)