Arctic Systems

READERS OF TAXATION will be familiar with the TA 1988 s 660A settlement drama:

Act 1: The Revenue launches surprise attack on small businesses

Act 2: The professional bodies mount massed counter-attack

Act 3: Battle begins: Jones v Goliath

Act 4: Trial or error — see below

Act 5: Dénouement — to be advised

Scene 1: Deadlock

[The curtain rises as the judgment in the Arctic Systems case is delivered to Mr and Mrs Jones's advisers Malcolm Gammie QC Dave Smith of Accountax and myself. Simon Juden of the Professional Contractors Group whose members funded the Jones's costs at the Special Commissioners is also present.]

The decision in the Arctic Systems case was deadlocked: of the two Special Commissioners Judith Powell found for the...