Salary sacrifice benefits and the National Minimum wage – another nail in the coffin?

Release Date Oct, 10 2009

Recently, we understand HMRC has taken legal advice relating to salary sacrifice schemes where some employees are excluded on the grounds of breaching certain legal requirements, like falling below the National Minimum wage and being under 18 (for Consumer Credit Act purposes for bikes to work). In order to be tax exempt, some benefits need to be offered to all employees and these salary sacrifice exemptions breach this.

Recently, we understand HMRC has taken legal advice relating to salary sacrifice schemes where some employees are excluded on the grounds of breaching certain legal requirements, like falling below the National Minimum wage and being under 18 (for Consumer Credit Act purposes for bikes to work).

In order to be tax exempt, some benefits need to be offered to all employees and these salary sacrifice exemptions breach this.  By clarifying this, HMRC is setting out their position and presenting a challenge to employers offering these types of schemes.  Whilst we have yet to hear how they will apply this in practical terms, employers should review their own arrangements and identify areas of risk.

There is news of some discussions taking place about changes to the rules associated with childcare vouchers to deal with this potential conflict but the recent announcement at the Labour conference that tax relief will be removed from this benefit from 2011 seems to imply that there is not a commitment to finding a long term solution.  We hope this changes as parents and employers are currently confused about what to do going forward.

Other benefits that might be caught by the NMW exclusion issue include bikes to work and bus tickets.  Some that can be offered to restricted groups of employees and do not need to meet the “available to all test” include parking at work, health screening and work related training.

This issue highlights the fact that benefit taxation and salary sacrifice were never designed to work in harmony and conflicts have been created with other legislation designed to protect employees.  It also reveals the lack of joined up thinking offered by various legal and taxation initiatives and one has to have some sympathy for HMRC trying to make sense of it all – OK, possibly not but certainly employers are having a tough time under the weight of complexity.

Whilst we need to hear more from HMRC and the Government about the way forward, we urge employers to review their arrangements and plan for the changes to be made.  Redbourne can help now by reviewing your current exposure and looking at your benefit plan designs to analyse the combination of salaries and benefit funding levels to see if there is an issue or not.  Solutions will need to cover enhanced benefit design and changes to your rules and we are confident there are ways forward which will help improve the overall plan rather than comprise it.

For more information please contact:

Richard Stewart
richard.stewart@redbourne.com
D +44 (0)20 8339 8822

Gillian Haworth
gillian.haworth@redbourne.com
D +44 (0)20 8339 8824

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