Arctic Systems Section 660A case delayed to spring

Those of you who have been following the Arctic Systems case, which is likely to be the first Section 660A test case before the Special Commissioners, may be wondering what has been happening.

For previous reports on this case see here:

Arctic Systems

It had been suggested that it might reach the Commissioners early in 2004. However, I understand that the case is now unlikely to reach the Commissioners before spring as the tax counsel appointed to represent Arctic, Malcolm Gammie, is apparently overseas until the middle of March.

It seems unlikely that the various parties involved, including the Special Commissioners will be able to find a common three day slot for the case until later in April or May.

By then of course we will know what IR591 intends with regard to the treatment of dividends within close companies like Arctic. Nevertheless, as with IR35, whatever IR591 brings there is likely to remain a number of Section 660A claims to work through the system before any new legislation takes effect.

www.UKTECH/section660

Kevin Miller, MA FCA