Commentary on Sections Schedule 7: Transitionals and Savings Part 3: Employment income: earnings and benefits etc. treated as earnings Paragraph 25
3669.Sub-paragraph (1) ensures that loans may be employment-related regardless of when they were made, even if that was before FA 1976 (which introduced the beneficial loans provisions) was passed. It derives from section 160(7) of ICTA.
3670.Sub-paragraph (2) derives from section 161(7) of ICTA. It has the effect that the provisions of section 188 which apply to “stop loss” arrangements do not apply in the case of a holding of shares acquired before 6 April 1976.