The Professional Contractors Group (PGC) has announced that the Arctic Systems case has been fast tracked through the Court of Appeal's lists, and will now be heard on 29 and 30 November 2005.
The case (Jones v. Garnett) had previously been scheduled for late January 2006. This was so close to the 2005 self assessment deadline that there would have been no hope for a judgement by the filing date.
Guidance issued by HMRC to date has been heavily criticised by the main tax bodies, and it is hoped that the outcome of the Arctic case will clear up several of the grey areas in HMRC's interpretation of S.660A. Unfortunately, the points that will be addressed are only in relation to limited companies, and subscribed shares.
If the decision goes in favour of HMRC, the earlier date will be of enormous...