Does my client need to register for PAYE?

I have a client who operates a chalet rental business in France. They pay their seasonal staff below the LEL of £97pw. However, they also provide some benefits to the employees such as accommodation (necessary for the job), a couple of meals a week, ski passes and ski insurance. 

Does my client need to operate PAYE? I understand that if all your staff are paid below the LEL, then registration for PAYE is not necessary but not sure if this is still the case if benefits are also provided. 

Can anyone help? Thanks in advance.