Jurisdiction(s):
United Kingdom

Key definition

Remuneration definition

What does Remuneration mean? Remuneration is the pay an individual receives for work, typically basic salary and, depending on context, variable elements such as bonuses, commission, overtime and allowances. It is a descriptive expression used across employment, company and tax law, with its precise scope set by the relevant statute, contract, policy or scheme rules rather than by a single universal legal definition. In pensions practice—particularly defined benefit schemes—the pension accrued is usually linked to pensionable remuneration (often called pensionable salary or pay). Whether remuneration includes or excludes bonuses, commission, overtime, car or location allowances, shift premia and other fluctuating emoluments is determined by the...

Disguised remuneration and UK employee share incentives: ITEPA 2003 Part 7A key concepts, exclusions, HMRC tax-advantaged plans and PAYE/NICs consequences for corporate lawyers

Published by a LexisNexis Corporate expert

Practice notes

This Practice Note describes:

the meaning of ‘disguised Remuneration’
how the disguised remuneration charge operates, and
the tax consequences of a disguised remuneration charge

This Practice Note is confined to the parts of the disguised remuneration regime that relate to Employee share incentives and is not a full commentary on the legislation. The Finance Act 2011 brought in Part 7A of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003), aimed at countering what has come to be widely called ‘disguised remuneration’ via employee benefit trusts. In broad terms, ‘disguised remuneration’ covers arrangements that use third parties (frequently employee benefit trusts) to provide value to employees in a manner that avoids or postpones liabilities to income tax and national insurance contributions (NICs). The use of a third party is essential for ITEPA 2003, Pt 7A to bite—where an employer grants a benefit straight to the employee (save where the employer is acting as trustee), ITEPA 2003, Pt 7A does not apply...

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Graham Muir

CMS

Graham Muir is a partner in CMS tax team with a 25-year track record of specialism in employee incentive scheme and employment tax issues.Graham advises quoted and unquoted companies on structuring, establishing and operating all forms of employee incentive scheme. He advises on the employer and employee tax, company law, corporate governance and regulatory issues arising out of such schemes (whether share based or cash based).Graham was a founder member of the HMRC Employment-related Securities Forum, is a member of the Consulting Tax Editorial Committee of LexisNexis and is Co-Chair of the Tax Committee of the Share Plan Lawyers group....

Web page updated on 21/05/2026

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