PART 2Reporting obligations

Employees13

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 200315 (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.