Income shifting consultation: Q5

In the consultation paper the Treasury says:

'B.47 It is the responsibility of individual 1 to determine the amount of income shifted and to make the appropriate adjustments for self-assessment purposes. The legislation deliberately does not prescribe a formula for quantifying the level of shifted income because the facts and circumstances will be different in each case.

B.48 HM Revenue & Customs (HMRC) expects individuals together with their advisers to use their own judgement in working out the level of shifted income. In doing so they must adopt a reasonable basis for any conclusions reached.'

Having listed as relevant factors the level of work carried out the capital introduced and the level of risk undertaken the section concludes:

'B.53 These questions are not intended to be an exhaustive list of the factors to be considered in assessing the amount of...