Arctic Systems maybe another example of the aggressive nature of HMRC when pursuing taxpayers, however, Arctic Systems is certainly not the first case in history where the Revenue ‘HMRC’ has pursued a taxpayer for arranging their affairs in a more beneficial manner for taxation purposes.
It brings to mind a case many years before I was born that led to Lord Clyde making the following statement:
"No man in this country is under the smallest obligation, moral or other, so to arrange his legal relations to his business or to his property as to enable the Inland Revenue to put the largest possible shovel into his stores.
The Inland Revenue is not slow – and quite rightly – to take every advantage which is open to it under the taxing statutes for the purpose of depleting the taxpayer’s pocket. And the taxpayer is, in like manner, entitled to be astute to prevent, so far as he honestly can, the depletion of his means by the Revenue".
Ayrshire Pullman Motor Services & Ritchie v CIR CS 1929 14 TC 754, Lord Clyde @ pp 764 or 765.