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I read the article Income shifting round table with considerable interest.
May I be permitted to inject a note of controversy into the discussion by observing that I agree entirely with the purpose underlying the draft legislation, albeit the technical details appear not to have been fully thought through.
I am an employee. I have no opportunity whatsoever to shift earned income to my wife, who is currently undertaking an arduous course of professional training (as a barrister).
When my wife is successfully established in her practice, she will have no opportunity to shift income to me.
Arctic Systems was, in my view, correctly decided in the House of Lords.
However, I see no justification for Mr and Mrs Jones being able to reduce their tax bill merely because they were able to structure Mr Jones's earning stream in a way denied to most of us.
