Taxes Consolidation Act 1997 Schedule 23 paragraph 9

Payment includes transfers of assets

Paragraph 9 of Schedule 23 provides that references to a "payment" in this Part of the Schedule include non-cash payments such as transfers of assets or other transfers of money's worth.

• References to "payment" are not limited to cash transactions but extend to any transfer of assets or other transfer of money's worth.
• This ensures that benefits delivered in non-cash form — for example, the transfer of shares, property, or other valuable assets — are caught by the charging provisions.
• The definition supports the tax charges imposed by Part 2 of Schedule 23, which apply where payments are made in breach of scheme approval conditions or after approval has ceased.
• The broad definition prevents avoidance of the charge to tax by structuring benefits as asset transfers rather than cash payments.