Benefits Code II: Not Low Paid Employees

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17A.1.2    To Whom does the Legislation Apply?

The rules apply to directors,7 whatever their salary (since they can fix their own income), and employees whose emoluments amount to £8,500.8 ITEPA section 216 expresses this rule negatively—the provisions do not apply to someone who is not a director and who earns less than £8,500; the gain from this reformulation is hard to see the figure of £8,500 was set in 1978.9 In 1989 it was decided that employees earning over £8,500 were no longer to be described as higher paid. In 2000 person earning the minimum wage of £3.60 per hour had annual income of £7,488. If the figure of £2,000 used in 1948 when the provisions were first introduced had been adjusted in line with earnings it would, by 1992, have risen to £73,080,10 and by 2000 £87,613.

17A.1.2.1    Director

The term ‘director’ is not restricted to directors formally appointed as such, but extends to those in accordance with whose instructions the actual directors act—with an exception for advice in a professional capacity.11 These shadow directors are liable whether or not they hold any office or employment.12 However, there are exclusions for (a) full-time working directors who do not have a material interest in the company and (b) directors of non-profit-making bodies and charities provided, again, they have no material interest in the company.13 Such persons may, however, be employees and so be caught if their emoluments amount to £8,500 or more.14

A directorship is full time if the director is required to devote substantially the whole of his time to the company in a managerial or technical capacity.15 A has a material interest if A can control more than 5% of the ordinary

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