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A discussion about the history and new proposals on income shifting, held in London on 28 February and chaired by MIKE TRUMAN
PARTICIPANTS (more details below):
- Keith Gordon Atlas Chambers (KG)
- John Hiddleston Vantis Tax (JH)
- Anita Monteith ICAEW Tax Faculty (AM)
- Richard Mannion Smith & Williamson (RM)
- Mike Truman Taxation (MT)
Beginnings
MT: Although we're not going to look at the Arctic Systems case itself I did want to begin by going back to the start of this whole problem. When so far as you know did husband and wife companies first start being picked up by HMRC for investigation?
RM: It's difficult to put a date on it but there certainly was a point where we became aware of the problem. We started to be more careful to fall within TA 1988 s 660A(6) — the husband traded for a while first ...
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