I had a feeling that might be the case. That page still leaves some possible alternatives, though, eg this exemption:
an employer is usually expected to provide accommodation for people doing that type of work (for example a manager living above a pub, or a vicar looking after a parish)
It seems unlikely, but worth looking at whether developing a sufficient culture of EA orgs offering accommodation might suffice the ‘usually expected’ criterion.
It also seems a bit vague about what would happen if the EA org actually owned the accommodation rather than reimbursing rent as an expense, or if a wealthy EA would-be donor did, and let employees (potentially of multiple EA orgs) stay in it for little or no money (and if so, in the latter case, whether ‘wealthy would-be donor’ could potentially be a conglomerate a la EA funds)
There seems at least some precedent for this in the UK in that some schools and universities offer free accommodation to their staff, which don’t seem to come under any of the exemptions listed on the page.
Obviously other countries with an EA presence might have more/less flexibility around this sort of thing. But if you have an organisation giving accommodation to 10 employees in a major developed world city, it seems like you’d be saving (in the UK) 20% tax on something in the order of £800 per month per employee, ie about £7600 per year, which seems like a far better return than investing the money would get (not to mention, if it’s offered as a benefit for the job, being essentially doubly invested—once on the tax savings, once on the normal value of owning a property).
So while I’m far from confident that it would be ultimately workable, it seems like there would be high EV in an EA with tax law experience looking into it in each country with an EA org.
I had a feeling that might be the case. That page still leaves some possible alternatives, though, eg this exemption:
It seems unlikely, but worth looking at whether developing a sufficient culture of EA orgs offering accommodation might suffice the ‘usually expected’ criterion.
It also seems a bit vague about what would happen if the EA org actually owned the accommodation rather than reimbursing rent as an expense, or if a wealthy EA would-be donor did, and let employees (potentially of multiple EA orgs) stay in it for little or no money (and if so, in the latter case, whether ‘wealthy would-be donor’ could potentially be a conglomerate a la EA funds)
There seems at least some precedent for this in the UK in that some schools and universities offer free accommodation to their staff, which don’t seem to come under any of the exemptions listed on the page.
Obviously other countries with an EA presence might have more/less flexibility around this sort of thing. But if you have an organisation giving accommodation to 10 employees in a major developed world city, it seems like you’d be saving (in the UK) 20% tax on something in the order of £800 per month per employee, ie about £7600 per year, which seems like a far better return than investing the money would get (not to mention, if it’s offered as a benefit for the job, being essentially doubly invested—once on the tax savings, once on the normal value of owning a property).
So while I’m far from confident that it would be ultimately workable, it seems like there would be high EV in an EA with tax law experience looking into it in each country with an EA org.
Have you got any examples of schools and universities offering free accommodation to staff? I’ve only heard of subsidised accommodation, and here—https://www.citizensadvice.org.uk/debt-and-money/tax/what-is-taxable-income/tax-on-benefits-in-kind/ - it says that the difference between the rent paid and market rate is taxable.