This was an "IR35" anti-tax avoidance case (avoidance of tax and NIC's by an individual providing services via his own service company where he would otherwise be an employee of that company's client). A Mr Hough provided his services via his own service company (Island Consultants) to an IT agency which was contracted to do work for the ultimate client, Severn Trent Water (STW). The Special Commissioner ruled that the anti-avoidance rules applied. Mr Hough would be an employee of STW under the hypothetical contract which the legislation required to be constructed.