The exercise of the Pensions Board discretion as to how contributions were treated could not be reviewed by the Appeal Commissioners . Kelsall v Investment Chartwork Ltd 1994 STC 33
In Clarke(HMIT) v British Telecom Pension Scheme Trustees and others 2000 STC 222 it was held that the sub-underwriting commissions applied for the purpose of the scheme would have been taxable under the UK equivalent of Schedule D Case IV and not as trading income.
