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If the intermediary conditions described in E4.1042 are met, the next step is to identify a chain of persons making payments and connecting the intermediary at the bottom with the client at the top¹. The person immediately above the intermediary in this chain is the 'fee-payer'. Payments down this chain are 'chain payments': they may be in money or money's worth or in the form of a benefit, and it must be reasonable to take the payment to be for the worker's services to the public authority client. A payment in money or money's worth is made at the time of transfer, and a benefit at the time of provision². Where there is a multiple purpose to a payment, a just and reasonable apportionment must be made³.

The essence of the scheme is then to deem the payment made by the fee-payer to the intermediary to be a payment of employment income to the worker, made at the same time