General donations (i.e. donations that are not directed at a psecific target) to the party that are spent paying staff directly would not be registerable in the register of members interests at all - on my reading of the guidance and rules.

The problem with the text of the guidance and rules arises only where there is a specified target for the donation.

Another problem is that the post of MP is not the same as the post of shadow minister ... when a person becomes a member of parliament, the are the representative of the people of the constituency that elects them; they are not the representative of the party for whom they stand.  The shadow ministerial post is held, not as a result of the status as member of parliament, but as a result of a position in the party.  Hence, the office is not an office that is occupied as a result of being a member of parliament - indeed members of the House of Lords can be ministers and shadow ministers and, arguably, a minister could be appointed from outside the Houses of Parliament altogether (although that hasn't been done, I believe, for over 100 years).

As a result, I am not sure that it is necessary, as a matter of interpretation of the rules, for the payment of these office costs to be registered at all.  This is, I accept, a matter of argument; but it is simply not right to assert that these were 'clearly registerable interests' or words to that effect; there is doubt as to whether they are registerable at all.

These gifts were, perfectly properly, registered with the EC; as the law required them to be. 

Of course, this could be said to be the political manifestation of the proliferation of regulation and rules brought about in the last 10 years - where similar arguments and discussions can be had about many areas of regulation.