Income tax – Earnings from employment. The taxpayer banks (UBS and Deutsche Bank) had set up schemes to pay employees' bonuses in such a way that they could avoid paying income tax and national insurance contributions. The schemes involved 'restricted securities' and so took advantage of the tax exemption benefits of Ch 2 of Pt 7 of the Income Tax (Earnings and Pensions) Act 2003. The Revenue and Customs Commissioners determined that income tax and national insurance had been payable. The First-tier Tribunal (Tax) dismissed the banks' appeals. The Upper Tribunal (Tax and Chancery Chamber) allowed UBS's appeal and upheld the scheme, while DB's appeal was dismissed as having failed to meet the requirements of s 429 of the Act. The Court of Appeal, Civil Division, found that both schemes had fallen within the regime under Ch 2 of the Act so had been eligible for the corresponding tax benefits.