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Issue:
4167
/
Categories:
Comment & Analysis
, Arctic Systems
, Jones v. Garnett
, Admin
, Income Tax
MARK MCLAUGHLIN considers the application of the income tax anti-avoidance rules on settlements to dividend waivers
KEY POINTS
- Dividend waivers are not directly referred to by the settlements legislation.
- When is a waiver a bounteous arrangement?
- An arrangement can be a single transaction.
- HMRC's approach to dividend waivers has been inconsistent.
They think it's all over … it is now!
This will be a familiar quotation to football loving readers of Taxation (or the more senior ones anyway) being the famous words from Kenneth Wolstenholme's BBC TV commentary in the closing moments of the 1966 World Cup in which England beat West Germany 4-2 after extra time to win the final.
When I hear that quotation these days it is tempting to draw an analogy in tax terms to the Arctic Systems case (Jones v Garnett [2007] STC 1536) regarding the income tax anti-avoidance provisions on settlements (ITTOIA 2005...
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