Jones v Garnett (Arctic Systems): another way of getting to the same result

Comments on the House of Lords judgment in Jones v Garnett (Inspector of Taxes), the Arctic Systems case, on whether dividends paid to the wife of the fee-earner in a small family company were subject to the settlements rules. Considers whether to establish a company with equal shareholdings amounted to a settlement, an element of bounty was present, but the wife's share was an outright gift and not substantially a right to income. Considers whether income-splitting between spouses under separate taxation is abusive. Examines the case for a comprehensive review of married couples' taxation.