Payments by a company to its employees upon a change to the terms and conditions of a pension scheme were ‘from’ the employment and therefore liable to income tax and National Insurance contributions. 

Summary 

Payments by a company to its employees upon a change to the terms and conditions of a pension scheme were ‘from’ the employment and therefore liable to income tax and National Insurance contributions (NICs). 

Background 

New employees of the appellant company were (since 2008) eligible to join a defined contribution (DC) scheme. Before then, employees were invited to join a retirement balance arrangement, and earlier still employees had been enrolled in a traditional final salary scheme. The retirement balance and final salary