There were two issues in this case. The first issue was whether contributions paid by the Appellant companies were immediately deductible from those companies’ profits or should have the tax deduction deferred within the terms of s.43(11) Finance Act 1989. The second issue was whether sub-funds and loan from sub-funds in respect of the individual Appellants were subject to Schedule E income tax using, amongst other things, the principles described in W T Ramsay v. IRC and MacNiven v. Westmoreland Investments Limited. The Special Commissioners decided in favour of the taxpayers on both points.Timothy Brennan KC and Hugh McKay appeared for the Respondents