[554Z5 Overlap with money or asset subject to earlier tax liability]
Income Tax (Earnings and Pensions) Act 2003 (2003 c 1) | Legislation

[554Z5  Overlap with money or asset subject to earlier tax liability]

[(1)     This section applies if there is overlap between—

(a)     the sum of money or asset (“sum or asset P”) which is the subject of the relevant step, and

(b)     a sum of money or asset (“sum or asset Q”) by reference to which, on an occasion that occurred before the relevant step is taken, A became subject to a liability for income tax (“the earlier tax liability”).

(2)     But this section does not apply where—

(a)     the earlier tax liability arose by reason of a step within section 554B taken in a tax year before 6 April 2011, and

(b)     the value of the relevant step is (or if large enough would be) reduced under paragraph 59 of Schedule 2 to FA 2011.

(3)     Where either the payment condition or the liability

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