Posted: 03 September 2007
Authors: Mike Truman
Issue: Online only
Categories: Update, News, Admin, Income Shifting, HMRC
Keywords: Arctic Systems, Jones v. Garnett

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HMRC say it would be 'inappropriate to enter into a running commentary' on Mike Truman's 'Changing horses' piece of 30 August 2007.

HMRC were invited to respond to Mike Truman's Comment article in last week's issue — 'Changing horses', Taxation, 30 August 2007, page 225 — particularly on the issue of why they had not consulted earlier on legislation to deal with so-called 'income-splitting companies', since it was clear from at least the beginning of last year that even a successful appeal in Arctic Systems would not go as far as HMRC want to.
HMRC replied that 'as the policy development process is ongoing, it would be inappropriate to enter into a running commentary at this time'. They then repeated the part of the ministerial statement which referred to fairness and clarity, and that it should be possible to avoid targeting 'commercial arrangements' through consultation. Advisers were also referred again to the guidance issued on 30 July in respect of open cases and previous years' returns.

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