Many tax advisers had been waiting with bated breath to see what the Chancellor was going to say about income shifting, and the draft rules that HMRC had put together following their defeat in the House of Lords in the Arctic Systems case.
It was our view – shared by many in the profession - that the draft rules were ill conceived, badly thought through and brought considerable uncertainty as to the tax bills faced by most owner managed businesses in the UK.
Amazingly, not only did the Budget speech contain no mention, but in 107 budget notes the subject was not mentioned either.
We understand that the implementation date has been pushed back by a year until April 2009, to allow for further consultation. This is to be welcomed, and hopefully it will be possible for this period to give rise to a more measured and workable approach.
