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In addition to the obvious pay elements of salaries or wages etc, money's worth (being the ability to convert something of monetary value into cash or put it to pecuniary account) will result in the relevant amount being subject to PAYE and taxable, as well as being within the Class 1 NIC charge. Where the employee 'applies' their earned income in a manner of their choosing (ie they direct that their earnings should be paid to someone else rather than to themselves), PAYE tax and NIC will in almost all circumstances be due. It is the character of the payment rather that the identity of the person to whom it is paid which is critical. For a discussion of this in the context of EBTs and similar structures see E4.1219B regarding the Rangers Supreme Court decision¹ and E4.1219D.

Where lower-paid workers are involved, the impact of the various types of state benefits such as universal credit, pension credit etc, should also be noted². Although these state benefit sums are exempt