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Since 1927 the leading authority on tax law, practice and administration


01 November 2006
Issue: 4082 / Categories: Forum & Feedback
Correspondence from readers on topical subjects.

Aggressive attitude on dividends

Further to Andrew Gotch's Meeting point on the PTP conference: 'Employment: Taxes Law and Enquiries' of 7 September 2006 (published in Taxation 19 October 2006 page 68) I should like to offer the following.
This issue was covered by Andrew Hubbard at the Tax Faculty conference this year and reference was made to Dawn Primarolo's Hansard statement. In the paragraph just before column 042 she says: 'If taxpayers use contrived arrangements to get round anti-avoidance legislation — to avoid paying the proper amount of tax and National Insurance — they cannot expect to be excluded from the charge. However it will be absolutely clear from what I say about the purpose test that this measure will not affect the taxation of those small businesses that do not use contrived schemes to disguise remuneration to avoid tax and National Insurance'.

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