Para. 4A of Sch. 4 of the Social Security (Contributions) Regulations 2001, SI 2001/1004 (‘the Contributions Regulations’) treats the employer as making payments that are in fact paid by an ‘intermediary’. The latter is defined as:

a person acting on behalf of the employer and at the expense of the employer;

a person connected with him (the regulations still define this by reference to ICTA 1988, s. 839, although this was repealed in April 2010 by CTA 2010 – alternatives are available in CTA 2010, s. 1122 and ITA 2007, s. 993 but are not yet mandated); or

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