Philip Green appears to have formally passed control of Arcadia, the Top Shop and Dorothy Perkins chain, to his wife Tina. According to The Guardian, the new ownership structure will save the Green family £150m in tax that would otherwise have been payable on the £460m dividend the retail group is paying them this year. If the same structure is applied to Mr Green's Bhs stores group it will generate a further £130m tax saving on the £400m dividends the business has paid to the Green family over the last three years.

Mr Green is a UK taxpayer, however his wife is resident in Monaco. If Mr Green controlled Arcadia through a Jersey trust and corporate structure the Inland Revenue could tax any dividend payments he received irrespective of where they were paid. But with Mrs Green having control of Arcadia, her Monaco residency means the dividends paid from that group will avoid any tax liability for the family.

"If his wife is the trust settlor in Jersey and she is Monaco domiciled then there is no tax to pay on the dividend," one tax specialist said. But Mrs Green has been closely associated with the Arcadia deal from the outset. The offer document for the acquisition said: "Taveta Limited is wholly owned by Philip Green's family who will make their investment in Taveta through Taveta Limited. The only director of Taveta Limited is Cristina Green.

There is now a question over the ultimate control of Mr Green's Bhs stores group. Its most recent accounts, for the year to March 2004, report: "P Green and his immediate family are the ultimate controlling party of Bhs Group." The controlling shareholder is Mr Green's Jersey based Global Textiles Investments. Bhs has channelled almost £400m in dividends to Jersey for the Greens over the last three years. The tax bill on those payments would be approaching £130m if Mr Green rather than his wife were the ultimate controlling party.