HMRC watch: Revised guidance on the settlements legislation

HMRC have now updated their guidance on the settlement legislation following the decision of the House of Lords in the case of Jones v Garnett “Arctic Systems”, which was made in favour of the taxpayer.

The changes to the guidance put Revenue practice in this area back to where the majority of tax agents thought it was prior to 2003.

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Comments

Echoed but

AnonymousUser | | Permalink

it is still worth being familiar with. There is more there than just the points in Jones v Garnett (dividend waivers and gifts to children for example) and I expect that HMRC will be looking for cases which are marginal to try and limit the effect of that decision. Partnerships maybe?

Double Non-Taxation

JackHarper | | Permalink

Examples 22 and 23 are the same. Have they left a taxable example out? Perhaps it went in the post on a CD.

Sharing of risk / "income split"

mikewhit | | Permalink

Any update on the threatened topic of "income splitting" ?

Encouraged in the USA and Isle of Man ....

any day now

oldersimon | | Permalink

I had expected the draft legislation and guidamnce to be out by now, though there is apparently a delay...but I'm sure they won't br long !

It is unlikely to leave much work for the settlements legislation to do, I suspect.