By Nichola Ross Martin
HMRC issued a statement on Friday, announcing its intention to appeal to the House of Lords against the Court of Appeal's ruling in favour of the taxpayer, in the case of Jones v Garnett, also known as 'Arctic Systems'.
Their statement says 'The (settlements) legislation applies in a wide range of circumstances, including income from small companies and partnerships but it does not apply to income from those companies and partnerships that have normal commercial arrangements.'
It seems therefore that HMRC will be intending to argue that the Joneses' business arrangements were neither normal or commercial. In HMRC's...