In the case of HM Revenue & Customs v PA Holdings Limited, PA wished to pay its employees discretionary annual bonuses. It adopted an arrangement whereby the employees were awarded shares in a special purpose company and received dividends. The effect, so PA contended, was that the cash the employees received was dividend income rather than employment income and should be taxed as such. Additionally, PA contended that there was no liability to make National Insurance Contributions (NICs) in respect of these payments.