Payments made to members of an entity (e.g. an LLP, company, CIC or charity) may be made for reasons other than being a member. This was held to be the case recently when an LLP made payments to partners (members) who were also former employees. The Upper Tribunal held that the payments were not partnership income but related to the time when the individuals were employees. They were therefore subject to PAYE, employees NI and employers NI in line with employment payments.