Taxing matters

06 September 2007 / Peter Vaines

Issue: 7287 / Categories: Features , Tax

ARCTIC SYSTEMS >>
CLARITY ON UK TAX LIABILITY FOR NON UK RESIDENTS >>
RECTIFICATION FOR TRUSTEES >>

ARCTIC SYSTEMS—THE FINAL SOLUTION

The House of Lords has now delivered judgment in Arctic Systems—otherwise known as Jones v Garnett (Inspector of Taxes) [2007] UKHL 35, [2007] All ER (D) 390 (Jul) and it makes interesting reading.
Mr and Mrs Jones each had one share in a company which provided computer consultancy services. Mr Jones did all the work with the clients; Mrs Jones did all the back room admin work; they took small salaries and had large dividends thereby minimising their liability to tax and national insurance contributions. HM Revenue & Customs (HMRC) said that it was not a commercial arrangement for Mr and Mrs Jones to hold one share each and to pay dividends in this way—it was an arrangement conferring bounty on Mrs Jones and therefore a settlement within the Income and Corporation Taxes Act 1988, s 660A (now the Income Tax (Trading and Other Income) Act (ITTOIA 2005), s 624) so that the whole of the income

If you are not a subscriber, subscribe now to read this content

If you are already a subscriber sign in

...or Register for two weeks' free access to subscriber content

Taxing matters

ARCTIC SYSTEMS >>
CLARITY ON UK TAX LIABILITY FOR NON UK RESIDENTS >>
RECTIFICATION FOR TRUSTEES >>

ARCTIC SYSTEMS—THE FINAL SOLUTION

If you are not a subscriber, subscribe now to read this content

If you are already a subscriber sign in

...or Register for two weeks' free access to subscriber content

SourceURL:

Links:

E-newsletter Sign-Up

MOVERS & SHAKERS

Read All

Quinn Emanuel Urquhart & Sullivan—Andrew Savage

Firm expands London disputes practice with senior partner hire

Druces—Lisa Cardy

Senior associate promotion strengthens real estate offering

Charles Russell Speechlys—Robert Lundie Smith

Leading patent litigator joins intellectual property team

NEWS

Read All

NLJ this week: Law Society calls for clarity on AML

The government’s plan to introduce a Single Professional Services Supervisor could erode vital legal-sector expertise, warns Mark Evans, president of the Law Society of England and Wales, in NLJ this week

NLJ this week: Turning corporate liability into opportunity

Writing in NLJ this week, Jonathan Fisher KC of Red Lion Chambers argues that the ‘failure to prevent’ model of corporate criminal responsibility—covering bribery, tax evasion, and fraud—should be embraced, not resisted

NLJ this week: A prince no more?

Professor Graham Zellick KC argues in NLJ this week that, despite Buckingham Palace’s statement stripping Andrew Mountbatten Windsor of his styles, titles and honours, he remains legally a duke

NLJ this week: Shareholder secrecy sunk

Writing in NLJ this week, Sophie Ashcroft and Miranda Joseph of Stevens & Bolton dissect the Privy Council’s landmark ruling in Jardine Strategic Ltd v Oasis Investments II Master Fund Ltd (No 2), which abolishes the long-standing 'shareholder rule'

NLJ this week: The expanding remit of national security law

In NLJ this week, Sailesh Mehta and Theo Burges of Red Lion Chambers examine the government’s first-ever 'Afghan leak' super-injunction—used to block reporting of data exposing Afghans who aided UK forces and over 100 British officials. Unlike celebrity privacy cases, this injunction centred on national security. Its use, the authors argue, signals the rise of a vast new body of national security law spanning civil, criminal, and media domains

Error message

Taxing matters

ARCTIC SYSTEMS—THE FINAL SOLUTION

ARCTIC SYSTEMS—THE FINAL SOLUTION

MOVERS & SHAKERS

Quinn Emanuel Urquhart & Sullivan—Andrew Savage

Druces—Lisa Cardy

Charles Russell Speechlys—Robert Lundie Smith