Many feared that HM Revenue & Customs would be quick to impose legislation to counter income-splitting arrangements in owner-managed businesses following its defeat in the landmark Arctic Systems case in 2007 - (strictly referred to as Jones v Garnett [2007] STC 1536). Some two years on, however, the law still stands where it was when the House of Lords ruled that Mr Jones' arrangements for routing tax-efficient dividends to his wife were effective.rnBefore the Arctic Systems case, HMRC often tried to apply the settlement legislation to 'husband and wife' companies where the wife was typically provided with shares and the dividends paid on those shares were largely derived from the profits earned by her husband. The couple's tax planning objective would be to benefit from the lower dividend tax rates enjoyed by the wife.
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机译:许多人担心,HM税务与海关总署将在2007年里程碑式的Arctic Systems案败诉后迅速采取立法,打击所有者管理的业务中的收入分割安排-(严格称为Jones v Garnett [2007] STC 1536) 。然而,大约两年后,法律仍然维持原状,当时上议院裁定琼斯先生将节税红利分配给妻子的安排是有效的。在北极系统案之前,HMRC经常试图适用和解协议。立法为“夫妻”公司提供法律,在该公司中,通常向妻子提供股份,而这些股份所支付的股息主要来自丈夫所赚取的利润。夫妻的税收筹划目标将是从妻子享有的较低的股息税率中受益。
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