HM Revenue & Customs' reinterpretation of S660A could penalise tens of thousands of jointly owned enterprises, often set up by married couples who share the burdens of running their businesses, but who HMRC now says are not entitled to share the rewards. This goes against the will of Parliament when introducing the independent taxation of spouses. Because the change is retrospective, businesses which have been set up in an entirely standard way, in line with prevailing practice and advice over many years, could be in receipt of tax bills of up to �40,000 covering six years.

Following the landmark ruling by the Court of Appeal in December 2005, HMRC's reinterpretation of the law is not valid and PCG's arguments have been vindicated. The House of Lords is due to give a final ruling on the issue within a year.

Introduction to S660A
The "S660A" controversy developed in 2003 when the Inland Revenue (now HM Revenue & Customs) announced a new interpretation of the long-established "settlements legislation". See here for a brief introduction.

PCG Guide to S660A
A full consideration of S660A from the contractor's perspective: includes advice on how to decide whether or not you are caught and what action to take, plus an up-to-date assessment of the current legal position.

PCG Policy Briefing: S660A
PCG believes that HMRC�s new interpretation of S660A is wrong in law and that attempting to levy retrospective taxation in this way is wholly unacceptable.

PCG Policy Briefing: S660A and Arctic Systems Ltd
Since 2003, PCG has been supporting Geoff and Diana Jones in challenging the reinterpretation of the settlements legislation. In 2005 the Court of Appeal ruled that they did not fall within it. This paper offers an overview of the case and its implications.