Income tax – Earnings from employment. There was nothing either in the wording of the Income Tax (Earnings and Pensions) Act 2003 or in the external material on which the taxpayer companies relied that supported their construction of the definition of a 'managed service company' (MSC) provider in s 61B(1)(d) of that Act. Consequently, the Upper Tribunal (Tax and Chancery Chamber) had correctly decided that the company which had set up the taxpayers was an MSC provider, so that the taxpayers were MSCs. Accordingly, the Court of Appeal, Civil Division, dismissed the taxpayers' appeal against the tribunal's decision.