Commentary on Sections Schedule 7: Transitionals and Savings Part 3: Employment income: earnings and benefits etc. treated as earnings Paragraph 31
3678.The charge to tax under section 199 of this Act may be in respect of a loan made before the tax year 2003-04. This paragraph translates the reference in section 199(4)(b) to “excluded employment” to the term “an employment to which Chapter 2 of Part 5 of ICTA applies” in the case where the shares were acquired before 6 April 2003.