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The next area of planning to be explored relates to payments to employed earners, ie employees and directors, the employment status of whom it is impossible or undesirable to change (and who do not wish to leave the UK to avoid liability). Mitigation or elimination of contribution liability in respect of such persons will primarily be achieved by turning to advantage the principles and regulations governing 'earnings'. The term has an everyday meaning that most people understand, but that meaning has been qualified in numerous ways for policy reasons over the years, so that opportunities for planning exist, some more complex than others.

First, it is worth considering the basics: 'earnings' for contribution purposes, as already noted, includes 'any remuneration or profit derived from an employment'¹. The broad definition has much in common with that of 'emoluments' for old Schedule E income tax purposes, albeit without a requirement for the profit to be money or have a money's worth or second-hand value. It is what a worker receives in return for acting as or being an