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When is a salary not a salary?

Orwellian thinking in the UKBA. The worked example towards the end of this FOI request showing the loss of tax revenue was based on the rate for the job being £30,000 which would have been listed in the UKBA salary rate tables. The business expenses the UKBA accepts towards the salary package rate for the job, required in order to issue the work visa would not be considered taxable salary by HMRC. So once the ICT worker is in the UK, HMRC will only be interested in the taxable part, which will not be very big if the migrant worker comes from a low cost country.

The discussion below is quite long but hang in there, the response from the UKBA dated 10/01/2011 is very telling.

Freedom of information request EFM 3136 - UKBA Tier 1 & Tier 2 - Analysis of salary package allowances paid to migrant workers

 

 

From: Peter Kellard
Sent: 01 December 2010 10:12 PM
To: Freedom Of Information Team ( IND )
Subject: UKBA Tier 1 & Tier 2 - Analysis of salary package allowances paid to migrant workers

 

Has there been any analysis by the UKBA that has shown that allowances paid to Tier 1 and Tier 2 workers as part of their salary packages could be used to undercut the appropriate rates paid to resident workers?

If such analysis has been conducted when was the analysis done?

If such analysis has been conducted has it ever been communicated to ministers or ministerial advisers of the current government?


Yours Sincerely


Peter Kellard

 

 

On 09/12/2010 16:29, Jackson Richard (Immigration Policy) wrote:

 

Dear Peter,

 

Thank you for your e-mail, which has been passed to me for a reply.

 

No UK Border Agency analysis has shown that allowances paid to Tier 1 and Tier 2 migrant workers could be used to undercut appropriate rates.

 

Tier 1 migrants have free access to the UK labour market and do not need a sponsoring employer. They are therefore free to take any job at any rate (provided it is lawful). A UK Border Agency study, published on 27 October, has shown that many of these workers are in low-skilled and low-paid jobs. Please see: www.ukba.homeoffice.gov.uk/sitecontent/newsarticles/2010/oct/79-highly-skilled-jobs

 

It is partly for this reason that the Government intends to close the Tier 1 (General) category from April 2011, and has proposed to close the Tier 1 (Post-Study Work) category as well.

 

Tier 2 migrants require a skilled job offer from a sponsoring employer before they can apply. It is a requirement that the sponsor pay a salary equivalent to the appropriate rate for resident workers. Our guidance for sponsors sets out which types of allowances we do and do not accept towards salary packages.

 

We do not allow tax exemptions in relation to allowances to be used to artificially inflate salary packages. The stated salary must be the amount the employer is actually paying.

 

Further details are available in the sponsor guidance: www.ukba.homeoffice.gov.uk/sitecontent/documents/employersandsponsors/pbsguidance/

 

Regards,

Richard

Richard Jackson
Immigration Policy
UK Border Agency
PO Box 3468, Sheffield, S3 8WA
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From: Peter Kellard
Sent: 10 December 2010 9:49 AM
To: Jackson Richard (Immigration Policy)
Subject: Re: EFM 3136 - UKBA Tier 1 & Tier 2 - Analysis of salary package allowances paid to migrant workers

 

Dear Mr Jackson,

As the gross salary a sponsoring employer quotes can include an allowance of 30% for migrant workers applying to work in the UK for over 12 months and 40% for those working less than 12 months. Will you provide me with the analysis referred to in your reply which shows that that these allowances included in the 'gross salary amount' paid to Tier 1 and Tier 2 migrant workers is not being used to undercut resident salaries.

Further your reply you have not answered my other questions ie

If such analysis has been conducted when was the analysis done?

If such analysis has been conducted has it ever been communicated to ministers or ministerial advisers of the current government?

Yours Sincerely


Peter Kellard

 

On 13/12/2010 17:03, Jackson Richard (Immigration Policy) wrote:

 

Dear Mr Kellard,

 

Our consideration of this issue is available on the archived version of the UK Border Agency website (see paragraphs 41 to 46): http://webarchive.nationalarchives.gov.uk/20100406043816/http:/www.ukba.homeoffice.gov.uk/sitecontent/documents/news/statement-of-policy

 

Accommodation makes up a substantial expense against most people’s wages (through rent or mortgage payments). It is therefore sensible to include a proportion of allowances paid for this purpose towards the overall salary package. To reiterate, this is money that employers are actually paying to employees.

 

Regards,

 

Richard

 

 

From: Peter Kellard
Sent: 13 December 2010 5:29 PM
To: Jackson Richard (Immigration Policy)
Subject: Re: EFM 3136 - UKBA Tier 1 & Tier 2 - Analysis of salary package allowances paid to migrant workers

 

Dear Mr Jackson,

You still have not answered my questions.

 

I am aware of the policy guidelines 41-46, I was after sight of the analysis upon which this policy is based not the policy detail.

You acknowledge in your first reply that such analysis does exists, will you forward this to me?. I also asked when was this analysis was conducted and has it been communicated to ministers or ministerial advisers of the current government?


Yours sincerely



Peter Kellard

 

 

On 15/12/2010 13:11, Jackson Richard (Immigration Policy) wrote:

 

Dear Mr Kellard,

 

No such analysis exists. We developed the policy in partnership with a number of the larger system users, UK Border Agency operational experts, and a prominent trade union.  In the circumstances we were content that speaking directly to users of the system was sufficient and no detailed analysis was required.

 

Regards,

 

Richard

 

 

 

From: Peter Kellard
Sent: 15 December 2010 1:46 PM
To: Jackson Richard (Immigration Policy)
Subject: Re: EFM 3136 - UKBA Tier 1 & Tier 2 - Analysis of salary package allowances paid to migrant workers

 

Dear Mr Jackson,

I notice that you have not mentioned HMRC. Did the UKBA seek any advice taken from the Inland Revenue with respect to the UKBA's interpretation of Salary when formulating this policy on allowances and substantive expenses. The definition used by the UKBA to get to a Salary amount which is then used for the resident market test to prevent undercutting resident workers salaries would not be allowed by HMRC for resident workers. Will you provide details of requests made to HMRC for clarification on this policy issue and any advice given by HMRC to such requests?

Will you provide details of the prominent trade union and the large systems users involved in the policy partnership?

Was there any guidance from ministers or ministerial advisers on including accommodation and other expenses into the salary figure?


Yours sincerely


Peter Kellard

 

 

On 15/12/2010 14:37, Jackson Richard (Immigration Policy) wrote:

 

Dear Mr Kellard,

 

We have on previous occasions discussed these issues verbally with HMRC, who advised us that tax exemptions apply to certain types of expenditure, regardless of whether the employee was paid the money relating to the expenditure as tax or allowances.

 

I am not sure what you mean when you say our definition would not be allowed by HMRC, since HMRC does not operate any sort of appropriate rate test.

 

For resident labour market test purposes, we are concerned with the total salary + allowances package that would be offered to resident workers.

 

For intra-company transfers we treat allowances slightly differently (as detailed in our guidance) because we recognise that there are good reasons why businesses would not want to alter an employee’s base salary when transferring them temporarily to the UK,  and would pay them a “UK cost of living” allowance instead. The total package must still be at least equal to the appropriate rate.

 

We spoke with the following organisations when developing the policy. Please note that the final policy decision was ours alone and not theirs, although we took their advice on board.

 

Accenture

Connect

IBM

Logica

PWC Legal

Sarah Buttler Associates

 

We have discussed the consideration of allowances with our current Ministers and they have confirmed to us that they are not minded to make changes. The Home Secretary stated in an answer to the House of Commons on 23 November that there will continue to be some allowance for allowances.

 

Regards,

 

Richard

 

 

From: Peter Kellard
Sent: 20 December 2010 12:00 AM
To: Jackson Richard (Immigration Policy)
Subject: Re: EFM 3136 - UKBA Tier 1 & Tier 2 - Analysis of salary package allowances paid to migrant workers

 

Dear Mr Jackson,

What I mean in that HMRC would not allow the gross salary amount you use for resident labour market test purposes, is that you are including elements within the migrant salaray package which HMRC would exclude from Tax and NI as they do not consider these elements as part of ones taxable pay, they are allowable business expenses. The UKBA resident labour market test then compares this amount against the salary ranges provided by Salary Services Ltd to ensure undercutting of resident workers does not take place. However my understanding is the salary figures provided by Salary Services Ltd which are used for this test do not include these non taxable allowances and so it is no a like for like comparison and therefore a meaningless test.

Will you confirm if the Salary figures provided by Salary Services Ltd and used by the UKBA in the resident labour test contain non taxable allowance components and if so what percentage?

After discussing these issues with HMRC and then finalising your policy did the UKBA ask HMRC to validate the policy model to ensure that businesses using migrant workers particularly ICT workers would not gain an advantage through reduced tax and NI due on the total salary package paid? Were any example scenarios worked through to ensure there were no such unintended consequences of the final policy?

What was the name of the prominent trade union invloved in developing this policy referred to below?


Yours Sincerely



Peter Kellard

 

 

On 10/01/2011 10:54, Jackson Richard (Immigration Policy) wrote:

 

Dear Mr Kellard,

 

As I mentioned in my previous e-mail, the advice we have had from HMRC is that detached duty tax relief is claimable for certain types of expenditure, and applies whether or not an employee is paid in salary or allowances.

 

Employers can (as an alternative to the employee claiming detached duty relief) arrange a tax dispensation on certain allowances with HMRC.  However, if they do this, we will not allow the employer to artificially inflate the size of the pay package on the basis of the tax that has not been paid.  This means that businesses cannot benefit financially from the reduced tax paid.

 

This tax relief applies to spending on accommodation, food, council tax, utility bills and travel to work from home for workers who are only coming to the UK for short periods. Every worker incurs these types of expenses, and therefore we see no logical reason to exclude money paid to migrant workers for these purposes, regardless of whether they are paid it in salary or allowances.

 

The salary figures provided by Salary Services Ltd are based on advertised salaries. There is nothing in their published methodology to state that allowances are specifically included or excluded.

 

Many businesses operate a salary model in which a migrant worker continues to be paid their overseas salary while they are working in the UK, and make up the difference to the salary that would be paid to a UK worker with a “UK cost of living allowance”.  This avoids the need to raise the employee’s base salary and then lower it again when they return overseas. We do not consider this practice to be unreasonable.

 

If you have concerns that businesses are avoiding tax that they should be paying, I suggest you raise the issue with HMRC.

 

As per my previous e-mail, we discussed our approach to salaries and allowances with the Connect union.

 

Regards,

 

Richard

 

From: Peter Kellard
Sent: 16 January 2011 12:00 AM
To: Jackson Richard (Immigration Policy)
Subject: Re: EFM 3136 - UKBA Tier 1 & Tier 2 - Analysis of salary package allowances paid to migrant workers

 

Mr Jackson,

For the purpose of the resident labour market test salary comparisons, what was the UKBA view on the data published by Salary Services and used in formulating its policy. Did the UKBA base its policy on the view that the advertised salaries included a component of detached duty relief?

Yours Sincerely


Peter Kellard

 

 

On 21/01/2011 14:53, Jackson Richard (Immigration Policy) wrote:

 

Dear Mr Kellard,

 

We draw on a wide variety of sources of salary data for different occupations under Tier 2.  Our policy on allowances and detached duty relief is not based on any one source of salary data used for a particular occupation(s).

 

Regards,

 

Richard

 

 

From: Peter Kellard
Sent: 24 January 2011 11:24 PM
To: Jackson Richard (Immigration Policy)
Subject: Re: EFM 3136 - UKBA Tier 1 & Tier 2 - Analysis of salary package allowances paid to migrant workers

 

Mr Jackson,

Irrespective of the variety of sources of salary data for different occupations under Tier 2. Did the UKBA base its policy on the view that the advertised salaries included a component of detached duty relief?

Yours Sincerely


Peter Kellard

 

 

On 25/01/2011 09:54, Jackson Richard (Immigration Policy) wrote:

 

Dear Mr Kellard,

 

We based our policy on the view that advertised salaries are an accurate indication of the total salary package on offer.  Whether an individual is entitled to a component of detached duty relief on part of that salary package will depend on their individual circumstances, rather than on the salary on offer to all applicants.

 

Regards,

 

Richard

 

 

From: Peter Kellard
Sent:
25 January 2011 12:56 PM
To: Jackson Richard (Immigration Policy)
Subject: Re: EFM 3136 - UKBA Tier 1 & Tier 2 - Analysis of salary package allowances paid to migrant workers

 

Mr Jackson,

So did the UKBA base its policy on the view that the advertised salaries were an accurate indication of the total salary package on offer and that they included a component of detached duty relief.

Yours Sincerely


Peter Kellard

 

 

On 25/01/2011 14:04, Jackson Richard (Immigration Policy) wrote:

 

Dear Mr Kellard,

 

Our view is that advertised salaries are an indication of the total salary package on offer, including any components that may be eligible for detached duty relief if the individual worker’s circumstances permit it.

 

Regards,

 

Richard

 

 

From: Peter Kellard
Sent:
25 January 2011 4:00 PM
To: Jackson Richard (Immigration Policy)
Subject: Re: EFM 3136 - UKBA Tier 1 & Tier 2 - Analysis of salary package allowances paid to migrant workers

 

Dear Mr Jackson,

You still have not answered the question, eligibility is not an issue as all employees can claim detached duty relief, there is no difference here between resident or migrant workers on this. An advertised salary will either have a component of detached duty relief or it will not, it cannot be both otherwise your policy will be inconsistent. Which position did the UKBA take with respect to advertised salaries having a component of detached duty relief ?


Yours Sincerely


Peter Kellard

 

 

On 25/01/2011 16:15, Jackson Richard (Immigration Policy) wrote:

 

Dear Mr Kellard,

 

My understanding of detached duty relief is that an employee transferred long-distance to fill a post may claim detached duty relief on certain expenditure, whereas an employee who lives and works locally, and is filling the same post at the same salary, cannot.  As an employer cannot know at the point of advertising whether (for example) the post can be filled locally or whether they will need to transfer an employee from an overseas branch, they cannot prejudge the detached duty relief component.

 

As stated in my previous replies, UKBA took the view that advertised salaries reflect the total salary package on offer.  This includes any components which may be eligible for detached duty relief.  To put it another way, if a salary includes an element which may be eligible for detached duty relief, we considered that this will have been included in the advertised rate.

 

Regards,

 

Richard

 

 

From: Peter Kellard
Sent:
25 January 2011 9:31 PM
To: Jackson Richard (Immigration Policy)
Subject: Re: EFM 3136 - UKBA Tier 1 & Tier 2 - Analysis of salary package allowances paid to migrant workers

 

Dear Mr Jackson,

I am a little confused by your reply.

You confirm that a resident local worker cannot claim detached duty relief as part of their salary and that a migrant worker can. You also say that an employer cannot prejudge the detached duty relief component when advertising a position. As the employer must advertise in the
UK first and a local worker cannot claim detached duty relief, the total salary package the employer advertises therefore cannot contain any components of detached duty relief.

Will you confirm that my understanding of your reply on this point is correct?


Yours Sincerely


Peter Kellard

 

 

On 26/01/2011 09:39, Jackson Richard (Immigration Policy) wrote:

 

Dear Mr Kellard,

 

I think we are saying the same thing.  The advertised salary will be the total salary package on offer.  Whether part of that salary attracts detached duty relief will depend on who takes up the post.

 

Regards,

 

Richard

 

 

From: Peter Kellard
Sent:
26 January 2011 10:59 PM
To: Jackson Richard (Immigration Policy)
Subject: Re: EFM 3136 - UKBA Tier 1 & Tier 2 - Analysis of salary package allowances paid to migrant workers

 

Mr Jackson,

I do not think we are saying the same thing.

Detached duty relief cannot be part of an employees salary as it is not subject to tax or national insurance. All workers, resident and migrant workers can receive payments which fall into the detached duty relief category, however receiving such a payment  does not make it salary. As the UKBA has a policy to ensure migrant workers do not undercut resident workers this boundary is important. The UKBA's interpretation of salary undermines its own policy in this area ( Appropriate Rates of Pay
http://www.ukba.homeoffice.gov.uk/employers/points/sponsoringmigrants/employingmigrants/residentlabourmarkettest/ ) of undercutting residents workers .

Using the UKBA's own example guidance on page 7 for a short term transfer (
http://www.ukba.homeoffice.gov.uk/sitecontent/applicationforms/pbs/tier2-guidance.pdf )  Lets consider the following illustration of including detached duty relief as 'salary' an whether a company would benefit under these guidelines to bring migrant workers into the country rather than hire resident workers :-

 

A company based in Sheffield has an assignment with a client in Reading for a period of 12 months less 1 day (a short term transfer). It requires 3 staff, it already has one resident worker on a salary of £30,000 in Sheffield. The company advertises for the other two positions at the same salary of £30,000. It fills one position from a resident worker who lives in Reading on a Salary of £30,000 and then brings in a migrant worker from outside the EU from one of its overseas offices. This migrant worker is paid a salary of £18,000. The staff member from Sheffield and the migrant worker are both paid £12,000 accommodation allowance (detached duty relief), the £12,000 paid to the migrant worker is considered by the UKBA as part of the workers salary and used to check the appropriate level of pay. The same £12,000 accommodation allowance paid to the resident worker is ignored by the UKBA and is not considered as part of the residents workers pay (HMRC would ignore the £12,000 accommodation allowance for both workers as it is not part of taxable pay it is detached duty relief).

Using a standard rate tax coding what is the total cost to the company for these workers, and how much will each of the workers receive after tax and NI has been deducted?

 

Picture

 

 

As you can see resident workers are undercut by 10.36% and 50.036%. Suppose the requirement in Reading is more involved than originally thought, and an extra 3 workers are required. What would any employer do with access to a pool of migrant workers who could fill these positions? When a company can bring migrant workers into the country following the UKBA's guidance and their costs will be less than recruiting or training resident workers that is exactly what they will do. The UKBA's policy in this area actively encourages undercutting of resident workers.

Will you confirm the above illustration is correct?


Yours Sincerely



Peter Kellard

 

 

On 31/01/2011 16:36, Jackson Richard (Immigration Policy) wrote:

Dear Mr Kellard,

 

You say, “All workers, resident and migrant workers can receive payments which fall into the detached duty relief category, however receiving such a payment does not make it salary”

 

The converse is also true.  Classing a payment as something other than salary does not make ineligible for detached duty relief.  Using your example, if a worker was paid £30,000 in salary and zero allowances, rather than £18,000 salary and £12,000 allowances, this would not affect the amount of detached duty relief that could be claimed.  It is therefore difficult to see what would be achieved by altering our current policy on allowances.

 

The requirement to advertise the job to resident workers applies to the Tier 2 (General) category.  Under this category, as per my previous e-mail, we only consider allowances that are also on offer to resident workers.  A salary package of £30,000 + £18,000 allowances is very different from a salary package of £30,000 including £18,000 allowances.  If the former is what is on offer to resident workers, we would expect to see that reflected in any job advertisement, or our Resident Labour Market Test will not have been met.  We would also expect that to be offered to any migrant worker being sponsored.

 

For the Tier 2 (Intra-Company Transfer) category, we accept allowances other than those on offer to resident workers for the reasons I have given in my previous e-mails.  However, this does not mean that it will be cheaper to hire a migrant worker.  The only difference in cost to the employer for your Reading example and your non-EU migrant example is that you have not included NI contributions.  NI contributions must be paid for migrant workers, either in the UK or (where a bilateral agreement between the two countries exists) the equivalent contributions in the sending country.  The cost to the employer may not be exactly the same in the latter case, but it will not be zero, and in any event it is not UKBA’s policy to interfere with international tax agreements.

 

Regards,

 

Richard

 

 

From: Peter Kellard  
Sent:
17 February 2011 12:25 AM
To: Jackson Richard (Immigration Policy)
Subject: Re: EFM 3136 - UKBA Tier 1 & Tier 2 - Analysis of salary package allowances paid to migrant workers

 

Dear Mr Jackson,

You have replied to my email but it appears you prefer to reword my illustration and then answer my questions using your version rather than addressing the points I have raised.

To help your understanding of my question, I will try a simpler example for you relating to migrant worker ICT's.

Two companies A & B have a client in Reading requiring IT resources for a period of 12 months less 1 day, all roles are the same and the 'rate' for doing the job is £30,000 pa.

Company A transfers a resident worker from
Sheffield onto the client site in Reading (think of this is an ICT within the UK). The company also has a Reading based resident worker working on the client site.

Company B has no workers in the
UK to fill the requirement so transfers a worker into the UK from outside the EU via the ICT route.

Company B must follow the UKBA guidelines to ensure the appropriate salary is paid. They can include allowances in addition to a base salary in a 'Salary Package' (as per your email
13/12/2010) to be used for job pay rate comparison purposes to meet the UKBA's rules before entry can be granted.

The illustration below was prepared by Accountants ExceedUK
  http://www.exceeduk.co.uk/

 

 

Picture

 


Contrary to your email of 13/12/2010 employees transferred into the UK are here on company business. These costs are incurred in the process of doing business, they should not be included for salary comparison purposes by UKBA as HMRC allows them to be tax free business expenses Travel, accommodation and subsistence expenses

As you can see company B follows the UKBA's rules which allow a 'salary package' of £30,000 to pass its salary comparison test and once in the UK uses HMRC's rules on businesses expenses. The result is a loss of Tax and NI revenue and the undercutting of resident businesses and workers. If the UKBA salary comparison test was valid the figures for company B employee should match those for company A employee from Sheffield.

Please advise if there are any errors in the figures in the illustration for the Company B migrant worker. I believe company B would meet all of the UKBA's guidelines to get to a 'salary package' which would be accepted as not undercutting the rate for the job by the UKBA under its current guidelines. You are incorrect in your reply below that NI will not be zero for such migrant workers
National Insurance for people coming to the UK

A rough calculation reveals that upward of £234 million of lost revenue (25,000 ICT migrant workers * £9,379) could be occurring if this was repeated Average Salary and Allowances from tier 2 ICT used CoS Q4 2010  &  (salary for programmers for November 2010 should read £26,804.15)

The recent advice of the Migration Advisory Committee on allowances was rejected by the government Immigration House of Lords written answers, 22 December 2010


You refer to discussions with current Ministers in your email of 15/12/2010 relating to allowances. You can see from the above illustration that the UKBA treatment of allowances will result in significant differences in Tax & NI revenue paid by non resident migrant workers and their companies compared to resident workers and companies.

 

What was the UKBA policy recommendation to Ministers on allowances during the above discussions?

 

During these discussions were Ministers presented with any figures or illustrations as above or any estimates to the Tax and NI revenue implications of the UKBA policy teams recommendations on allowances?



Yours Sincerely


Peter Kellard

 

 

Date: Thu, 17 Feb 2011 10:49:56 -0000 [2011-02-17 10:49:56 GMT]

From: Jackson Richard (Immigration Policy)

To: Peter Kellard

Subject: RE: EFM 3136 - UKBA Tier 1 & Tier 2 - Analysis of salary package allowances paid to migrant workers

 

Dear Mr Kellard,

 

I understand the point you are making, but you are overlooking two key factors:

 

(i)                   Salary packages reflect the cost of living.  It is reasonable for a worker transferred from, say, Bangalore to Reading to be paid to cover the cost of living in Bangalore and in Reading. However, there is no rationale in requiring them to be paid to cover the cost of living in Sheffield and in Reading, and so drawing a direct cost comparison with a transfer from Sheffield would be flawed.  As long as the transferee from Bangalore was paid at least the appropriate rate for a local worker, we would consider this acceptable.

 

(ii)                 “Total cost to employer” is the line in your table that we would look at, not the total cost before taxes.  As long as the figure in this line meets the UK appropriate rate (as detailed in our codes of practice for sponsors) we will accept the salary package on offer.  So in the Company B example, if the UK appropriate rate for the job on offer was £30,000, the application would be granted.  If the UK appropriate rate was £33,000, the application would be refused.

 

I have considered your request for precise details of policy discussions with Ministers, and on balance I do not consider that it would be appropriate to disclose these.  There is a public interest in Ministers and officials having space to hold candid discussions, challenge ideas and develop policy, and as such these discussions may be exempted from disclosure under section 35 (1)(a) of the Freedom of Information Act 2000. This allows us to exempt information if it relates to the formulation or development of Government policy.

 

I have answered your other questions and explained our policy in my previous e-mails.  There is little further I can add and I believe that there is little merit in continuing this e-mail discussion further.

 

Regards,

Richard

Richard Jackson
Immigration
Policy
UK Border Agency
PO Box 3468, Sheffield, S3 8WA
P
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