It follows the Arctic Systems case earlier this year, when the House of Lords dismissed HM Revenue & Customs' (HMRC) appeal against the decision not to tax the business on dividends that owner Geoff Jones paid to his wife Diana, The Independent reported.

Chancellor Alistair Darling has proposed draft rules to stop this happening, which will come into effect in April next year.

He said it was "unfair" that some people were able to arrange their affairs to allow them to take advantage of a lower rate of tax, but not everyone was able to do so.