A lawyer for two Christchurch surgeons, who the Inland Revenue Department alleges structured their finances to avoid paying tax, says the pair did nothing wrong.
The department has asked the Court of Appeal to overturn a High Court decision which found in favour of the surgeons.
The men, Ian Penny and Gary Hooper, formed companies and employed themselves, but the department says they gave themselves a "pay cut" on paper of up to 80%, or several hundred thousand dollars, in order to pay less tax.
However, the surgeons' lawyer compared their financial structure with some investment vehicles, which are also structured in a way that leads to the payment of less tax.
He said the High Court judge made the right decision and upheld principles already established in earlier similar cases.