Robert Venables QC and James Henderson (instructed by Slaughter & May) for the appellant.
Employment – Remuneration – National insurance – Appellants conferring bonuses on directors in form of beneficial interest in commodity with no recognised trading market – Directors selling back commodity following day – Secretary of State applying tax principle to transactions – Secretary of State determining transactions payment of earnings for national insurance purposes – Whether tax principle applicable to national insurance – Whether bonuses payments in kind or earnings – Social Security (Contributions) Regulations 1979, reg 19(1)(d).