Regulation 27 Payments to directors which are to be disregarded

by a company;

to or for the benefit of a director of that company;

in respect of any employed earner’s employment of that director with that company; and

in respect of which paragraph (2), (3) or (4) is satisfied.

the director is a partner in a firm carrying on a profession;

being a director of a company is a normal incident of membership of that profession and of membership of the firm of the director;

the director is required by the terms of his partnership to account to his firm for the payment; and

the payment forms an insubstantial part of that firm’s gross returns.

the director was appointed to that office by a company having the right to do so by virtue of its shareholding in, or an agreement with, the company making the payment;

by virtue of an agreement with the company that appointed him, the director is required to account for the payment to that company; and

the payment forms part of the profits brought into charge to corporation tax or income tax of the company that appointed the director.

the director was appointed to that office by a company other than the company making the payment;

by virtue of an agreement with the company that appointed him, the director is required to account for the payment to that company;

the payment forms part of the profits brought into charge to corporation tax of the company that appointed the director; and

the company that appointed the director is not one over which—

control.

“company” has the meaning given by section 832(1) F1... of the Taxes Act (interpretation of the Tax Acts) F2and Part 2 of Schedule 1 to ITEPA 2003;

“the director” means the director to or for the benefit of whom the payment referred to in paragraph (1) is made; and

in paragraph (4)(d)—