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UK PARLIAMENT · SITTING

Victoria Atkins

MP for Louth and Horncastle · Conservative · United Kingdom

IN THEIR OWN WORDS

Oh dear. This may be the last time the Secretary of State gets to give such an inadequate answer to what is a reasonable question about her grip on her Department. But let us look at Labour’s wider chaos.

TOPICAL QUESTIONS · 2026-07-09 · READ IN HANSARD

In recent weeks, DEFRA’s quangos have made headlines: the Environment Agency is failing to prosecute waste criminals, instead going after virtuous volunteers who are cleaning up the rivers for it; Natural England is demanding more madcap fish schemes at Hinkley Point C, on top of its recommended £700 million fish disco policy, all of whic…

TOPICAL QUESTIONS · 2026-07-09 · READ IN HANSARD

There are many questions still left unanswered in this report, and I hope that the Secretary of State will try to answer them rather than deflect, because that has been noticed. The plan looks to double the funding for Environment Agency inspections. Why are this Government focusing on bureaucracy rather than helping farmers survive?

FARMING ROAD MAP AND PROFITABILITY REVIEW · 2026-06-24 · READ IN HANSARD

In another leap from reality, the Government’s negotiations with the EU get barely a mention in this document, despite the enormous consequences they will have for farming businesses. CropLife UK has estimated that this EU reset could drain £810 million from UK farms and sacrifice almost 9,000 jobs from our rural constituencies.

FARMING ROAD MAP AND PROFITABILITY REVIEW · 2026-06-24 · READ IN HANSARD

We Conservatives view DEFRA as a vital economic Department, so we agree with its efforts to recalculate farming and food producers’ contributions to the economy. By the way, I note that Reform calls itself the farmer’s friend, yet there is not a single Reform MP in the Chamber.

FARMING ROAD MAP AND PROFITABILITY REVIEW · 2026-06-24 · READ IN HANSARD

As Labour MPs and Ministers in the Department for Environment, Food and Rural Affairs voted repeatedly for the family farm and family business taxes, DEFRA Ministers shut down farming payments without notice, including the SFI. Sadly, the record of this Government is rising food prices and a record number of farms closing.

FARMING ROAD MAP AND PROFITABILITY REVIEW · 2026-06-24 · READ IN HANSARD

The complete record

Every one of 6,012 lines we hold for Victoria Atkins, in date order, each linked to its source. Free to read, in full, without an account. Page 20 of 121.

  1. I am extremely grateful to my hon. Friend, who had a very successful business career before he was rightly elected to this place. He makes a really interesting point about spreading the benefits and how they do not just need to be financial, as he says. They can also be about career development. I recently visited John Lewis on Oxford Street. Although it has a different model of—

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  2. Yes, Ms McVey; the trip to John Lewis will have to come later. I am helpfully informed that, as set out in the TIIN, the additional resource will be dedicated to compliance work to support effective delivery and implementation of the measure. That is expected, as the hon. Member for Ealing North said, to cost a total of £570,000, but we will write to him with further details in due course.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  3. I am mindful that when the hon. Member asked me quite a technical question in a Statutory Instrument Committee recently, he misunderstood my response and raised a point of order that turned out to be wrong. I had to correct him on the record and with a letter to the Library, so I am pleased to be able to write to him on this matter to ensure that I have answered his question and that he understands the answer.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  4. I got it right. That was the point. He raised a point of order that was wrong. Question put and agreed to. Clause 16 accordingly ordered to stand part of the Bill. Clause 17 ordered to stand part of the Bill. Clause 26 Payments under Jobs Growth Wales Plus Question proposed, That the clause stand part of the Bill.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  5. The clause clarifies that payments made under the Welsh Government’s Jobs Growth Wales Plus scheme are exempt from income tax, with retrospective effect from 1 April 2022. The scheme was introduced by the Welsh Government on 1 April last year to replace traineeships and Jobs Growth Wales. The changes made by the clause will exempt from income tax payments made by way of training allowances under the scheme. Without the clause, the payments would be taxable, which would not be in line with the treatment of payments made for other training allowances.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  6. I am happy to be able to tell the hon. Lady that they were exempted. In terms of costs, I see the word “negligible” in the Exchequer impact assessment, so that is the administrative side effect of what we are trying to achieve to support efforts to train young people in Wales, which are commendable and for which I welcome the support. Clause 27, which I do not think we will debate, allows us to clarify the treatment of devolution payments via statutory instrument, which we are keen to do. Indeed, the hon. Lady will know that significant work with the Scottish Government, led by the Chief Secretary to the Treasury, is going on across the Treasury to underpin the arrangements for the fiscal framework.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  7. I can confirm that. Question put and agreed to. Clause 26 accordingly ordered to stand part of the Bill. Clause 28 Qualifying care relief: increase in individual’s limit Question proposed, That the clause stand part of the Bill.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  8. I hope that that will be a welcome improvement to the tax position of foster carers and shared lives carers. I therefore commend the clause to the Committee.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  9. The measure increases the amount of income tax relief available for foster carers across the UK and shared lives carers using qualifying care relief from £10,000 to £18,140 per year, plus £375 to £450 per week for each person cared for. Those thresholds will be index linked to the consumer prices index. That will benefit more than 33,000 individuals who receive care income in respect of foster caring and other types of care and who currently submit self-assessment returns; such people look after an estimated 58,000 foster children. We expect to take most care income out of tax by providing a higher level of relief. It will have simplification benefits, because it will allow more carers to use the simpler method of completing their self-employment pages on their self-assessment return.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  10. Minimum fostering allowances are set to rise by 12.4% in this financial year, and with current tax threshold freezes, current qualifying care relief levels are expected to push approximately 1,500 carers into tax, which could disincentivise care. We are seeking to reflect the higher allowances that are paid to carers and the higher costs of caring compared with when the relief was set originally. By linking the value of the relief to inflation, the measure will also help to ensure that the level of qualifying care relief remains appropriate over time, supporting carers now and in the future. This will help to provide a greater financial incentive for carers to join or stay in the care industry, improving the recruitment and retention of carers in the future.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  11. The clause makes changes to support foster carers by increasing the amount of income tax relief available to them and ensuring that that relief stays at an appropriate level over time in line with inflation. We are nearly doubling the qualifying care relief threshold, which will give a tax cut to a qualifying carer worth an average of £450 a year. I know that hon. Members are particularly interested in supporting foster carers, who are real public servants, in looking after looked-after children. Qualifying care relief has been unchanged since 2003. Many carers are now paying income tax on payments intended to represent the additional costs of fostering that qualifying care relief was intended to exempt.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  12. We use CPI across the board. What we have tried to do is bring the value of the QCR back to its intended level. As I said, it had not changed since 2003. Index linking protects its value to foster carers in the future, so that a future Finance Bill Committee does not have to consider a similar uprating in the future.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  13. It is because that tends to be our measure across the board. I take the hon. Lady’s point about housing, but if someone needs help with the cost of housing, depending on their income levels, there are other ways in which they can get help from the state for that. This relief was specifically to reflect the extraordinary public service that families across our constituencies provide in helping those most vulnerable of children. Question put and agreed to. Clause 28 accordingly ordered to stand part of the Bill Clause 29 Estates in administration and trusts Question proposed, That the clause stand part of the Bill.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  14. Part 2 of the schedule introduces a tax-free amount for trusts and estates with an income of £500 or less in a tax year. That frees smaller trusts, and around one in every seven estates with income, from paying and reporting income tax. The tax-free treatment for estate income is also passed on to the estate’s beneficiaries. For groups of trusts, the £500 limit will be reduced to a minimum of £100 per trust. That will prevent individuals from splitting up their investments into multiple small trusts to build up an inappropriate amount of tax-free income. We have tabled amendment 4 to simplify that rule. It excludes certain pension schemes from consideration when determining the amount of any reduction to a trust’s £500 tax-free amount.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  15. Last year, HMRC consulted on proposals to formalise and extend the concession, and on related reforms that would apply to smaller trusts and estates. Respondents broadly welcomed the proposals. We published a summary of the responses to the consultation at the spring Budget and are proposing legislation in line with that publication. The changes made by clause 29 and schedule 2 will provide greater certainty and simpler tax administration for trusts and estates. Part 1 of the schedule makes technical amendments relating to income distributed from a deceased person’s estate to a beneficiary. Those ensure that the beneficiary’s tax credits operate correctly, and that a person can use their savings allowance against distributed savings income.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  16. Clause 29 and schedule 2 make changes to provide greater certainty and simpler tax administration for trusts and estates by legislating and extending an existing concession. The changes prevent trusts and estates having to report small amounts of income tax to HMRC, make tax calculations more straightforward for some trustees, and provide technical clarifications for estate beneficiaries. Trustees of trusts and personal representatives of deceased persons’ estates do not have tax allowances in the same way that individuals do. As a result, they must send HMRC a self-assessment return for all income, even small amounts. HMRC operates a narrow concession so that trustees and personal representatives do not have to report small amounts of untaxed savings income.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  17. The measure does not affect the need for trust beneficiaries to consider their tax reliability on their trust income. On the hon. Member for Aberdeen North’s question, the amendment clarifies our intentions.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  18. I am told that the Chartered Institute of Taxation agreed with that proposition, and the Association of Taxation Technicians saw that as largely a question of timing and did not see a particular issue with the principle. The hon. Member for Ealing North asked about vulnerable beneficiary trusts. The measures are a simplification for those trusts, as for any other low-income trust, as there will no longer be the need to elect to have income taxed as if for vulnerable beneficiaries. Instead, the income will simply not be taxed as it arises. Most vulnerable beneficiary trusts are, indeed, discretionary trusts, and as I said earlier, both the Chartered Institute of Taxation and the Association of Taxation Technicians have opined on this.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  19. On the simplification point, the replacement of the lower-rate band with the new tax-free amount supports our long-standing goal of a modern and simpler tax system. This is a simplification for low-income discretionary trusts, as income within the tax-free amount will no longer be taxed as it arises. The change also simplifies calculations when income distributions are made. The consultation last year outlined that where discretionary trusts make income distributions, the existing 45% credit given to beneficiaries with that income would remain, as would the continued need for trustees to top up their payments to HMRC to match that credit when the distribution is made.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  20. Schedule 2 Estates in administration and trusts Amendment made: 4, in schedule 2, page 291, line 38, at end insert— “(za) the property comprised in the settlement is not held for a pensions purpose within the meaning of paragraph 7(3) of Schedule 1C to TCGA 1992 (property comprised in settlements held for a pensions purpose);”—( Victoria Atkins .) This amendment would mean that a pensions settlement could not be a “qualifying settlement” for the purposes of section 24B of the Income Tax Act 2007 (being inserted by the Bill) or a “relevant settlement” in respect of which the conditions in subsection (9) of that section could be met . Clause 30 Transfer of basic life assurance and general annuity business Question proposed, That the clause stand part of the Bill.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  21. I will repeat exactly what I said for the hon. Gentleman, slowly: the measure does not affect the need for trust beneficiaries to consider their tax reliability on trust income that they receive. Question put and agreed to. Clause 29 accordingly ordered to stand part of the Bill.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  22. These clauses address a possible mismatch within the life insurance tax rules and clarify the scope of existing legislation, facilitating commercial transactions and protecting vital Exchequer revenue. They also ensure that write-down orders are a viable option for insurers in financial distress, and do not cause any additional tax liability for either the insurer or the individuals who hold policies with those insurers. I therefore recommend that the clauses stand part of the Bill.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  23. The clause also prevents the insurer from claiming a tax deduction where a write-down order is subsequently varied or terminated, which ensures that when an insurer recovers, the overall impact of the clause is tax neutral. Clause 33 will extend the circumstances in which a pre-6 April 2015 lifetime annuity or a dependants annuity under a registered pension scheme can be reduced under a section 377A write-down without incurring unauthorised payments charges. This will ensure that those who receive financial services compensation scheme top-up payments, following a write-down under proposed new section 217ZA of the Financial Services and Markets Act 2000, will not face a tax disadvantage.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  24. It amends section 92 of the Finance Act 2012 so that it does not apply where substantially all the insurance risks of a book of BLAGAB are reassumed by a reinsurer. Clause 32 addresses the corporation tax consequences that could otherwise arise when an insurer’s liabilities are written down under proposed new section 377A of the Finance Services and Markets Act 2000, and when there is any subsequent write-up under proposed new section 377I of FSMA. Without the clause, any release of liabilities could lead to an undesirable additional tax charge, which would reduce the balance sheet benefits of the write-down. The changes therefore help to ensure that the ailing insurer avoids insolvency.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  25. Clause 30 addresses a possible tax mismatch arising from the rules applying to the reinsurance of BLAGAB, which can result in a loss of corporation tax when a court-approved transfer of BLAGAB is preceded by reinsurance. In that situation, the clause classifies and taxes the reinsured business as BLAGAB in the hands of the reinsurer, ensuring that profits are taxed on a consistent basis. By protecting the Exchequer in such a way, this measure will increase receipts by £50 million to £60 million per annum. Clause 31 addresses an industry concern that the current scope of the legislation, which treats certain sums received under a reinsurance contract as taxable income, may be unnecessarily wide and is blocking commercial transactions.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  26. They address the risk of both tax loss and unfair outcomes for insurers that could otherwise arise from commercial transfers of BLAGAB from one insurer to another. Insurers writing BLAGAB are charged corporation tax under the “income minus expenses” basis of taxation, which seeks to tax the shareholder profits and the policyholder investment return together as a single taxable amount. When a BLAGAB book is reinsured prior to the transfer of a business, the shareholder profit and policyholder investment return become separated and are taxed differently, which could result in a tax mismatch. Clauses 32 and 33 prevent unintended tax consequences arising for both the insurer and individuals in the event of a court-directed write-down, which will help to ensure that such write-downs are a viable option to insurers in financial difficulty.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  27. Clauses 30 and 31 address two issues concerning the tax rules that deal with reinsurance of a specific type of long-term insurance business known as basic life assurance and general annuity business, or more commonly, BLAGAB. Clauses 32 and 33 address the corporation tax and pension tax consequences that will arise from proposed new schedule 12 of the Financial Services and Markets Act 2000, which amends the procedure for a court-ordered write-down of an insurer’s liabilities when an insurer is in financial distress. Clauses 30 and 31 were originally announced by the Economic Secretary to the Treasury in a written ministerial statement on 15 December 2022 and applied with effect from that date.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  28. Clause 31 addresses a matter brought to HMRC’s attention by the insurance sector, which has a long-standing concern that the current scope of the legislation, which treats certain sums received under a reinsurance contract as taxable income, may be unnecessarily wide and is blocking commercial transactions. In relation to the hon. Lady’s laments about the simplification of financial services legislation, I speak with the scars of having tried to prosecute insider dealing cases in my time, so I can understand why she asks about that. Question put and agreed to. Clause 30 accordingly ordered to stand part of the Bill. Clauses 31 to 33 ordered to stand part of the Bill. Clause 34 Corporate interest restriction Question proposed , That the clause stand part of the Bill.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  29. First, in answer to the hon. Member for Ealing North, the Exchequer impact is plus-£15 million for 2022-23—all the figures are positive—plus-£50 million in 2023-24, plus-£55 million in 2024-25, and the same for 2025-26 and 2026-27. That is how long the measure has been scorecarded for. The hon. Member for Wallasey asked whether the risk was possible or actual. We legislated before significant further risk could arise on the adoption of the new accounting standard, IFRS 17. Clause 30 addresses a possible tax mismatch in the BLAGAB reinsurance rules.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  30. They remove unnecessary constraints and administrative burdens. The third group of changes make amendments to the qualifying asset-holding companies regime, making it more widely available to investment fund structures that fall within its intended scope. It is right that, after six years, the Government review the corporate interest restriction rules and address issues brought to our attention. That is what these clauses and schedules serve to deliver.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  31. At Budget 2020, we launched a review of UK investment funds’ taxation and regulatory rules. That led to the introduction of a new tax regime for qualifying asset-holding companies in April last year. Clause 35 and schedule 4 make targeted changes to that regime, to address issues raised by industry. They also make reforms to other tax regimes for investment vehicles that invest in UK property. There are many changes, including, first, to amend the “genuine diversity of ownership” condition in the tax regimes for qualifying asset-holding companies and real estate investment trusts, as well as the non-resident capital gains tax rules that apply to overseas collective investment vehicles. The second group of changes make targeted amendments to the REIT rules, to address issues raised by industry following a call for input in April 2021.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  32. I will not go through all five, but they include ensuring that groups cannot reallocate amounts of disallowed financing costs to reduce or eliminate a corporation tax inaccuracy penalty for careless or deliberate errors, and confirming that groups containing charities cannot benefit from tax relief for financing costs incurred in respect of tax-exempt activities. In most cases, the changes implemented by the Bill will take effect for periods of account starting on or after 1 April 2023. The Government have also tabled amendment 5, which concerns the definition of an insurance company for the purpose of the corporate interest restriction rules. The amendment ensures that the legislation has the desired effect, and I am told that it is supported by the Association of British Insurers.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  33. Therefore, on their introduction, the Government committed to keeping the rules under review, and in July last year HMRC set up an external working group to consult on proposed amendments to address issues raised by businesses and their advisers. Following that consultation, we are introducing clause 34 and schedule 3 to make a total of 21 amendments to the corporate interest restriction and related rules limiting deductions for finance costs. There are five changes that protect the Exchequer’s position.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  34. Clause 34 and schedule 3 make changes to the corporate interest restriction and connected rules in order to protect Exchequer revenue, remove unfair outcomes and reduce administrative burdens for businesses. Clause 35 and schedule 4 amend tax rules for real estate investment trusts, qualifying asset-holding companies, and overseas collective investment vehicles that invest in UK property. On clause 34, the UK’s corporate interest restriction rules prevent groups from using financing expenses to erode their UK tax base, where those expenses are not aligned with a group’s UK taxable activities. The Government estimate that the rules have increased corporation tax receipts by over £1 billion per annum since they were introduced in April 2017. The rules can be complex because they operate at both worldwide group and individual entity level.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  35. Schedule 3, as amended, agreed to. Clause 35 ordered to stand part of the Bill. Schedule 4 agreed to. Ordered, That further consideration be now adjourned . —(Andrew Stephenson.)

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  36. Amendment made: 5, in schedule 3, page 309, line 4, leave out paragraph 28 and insert— ‘28 (1) In section 494 of TIOPA 2010 (other interpretation), at the end insert— “(3) The definition of “insurance company” in section 65 of FA 2012 (which is applicable to this Part as a result of section 141(2) of that Act) has effect for the purposes of this Part as if, in subsection (2)(a), the reference to Part 4A of the Financial Services and Markets Act 2000 included a reference to the law of a territory outside the United Kingdom which is similar to or corresponds to that Part.” (2) In Part 7 of Schedule 11 to that Act (index of defined expressions), in the entry relating to an insurance company, in the second column, for “section 141 of FA 2012” substitute “section 494(3)”.’— (Victoria Atkins.) This amendment secures that companies count as insurance companies for the purposes of the corporate interest restriction rules if they effect or carry out contracts of insurance and have regulatory permission to do so under a foreign law which is similar to or corresponds to the relevant United Kingdom law.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  37. The corporate interest restriction rules superseded the tax treatment of financing cost and income rules, commonly referred to as the worldwide debt cap, but there are still open inquiries and cases in litigation where the debt cap legislation is in point. The changes clarify that a revised statement of disallowances is ineffective unless a revised statement of allocated exemptions is also submitted, so exemptions must always be reduced in line with disallowances. Question put and agreed to. Clause 34 accordingly ordered to stand part of the Bill. Schedule 3 Corporate interest restriction etc.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  38. We are making these changes because, as I have said, we are mindful that this is an incredibly complex area of law and of corporate accountability and we are genuinely happy to listen to businesses when they tell us that there are problems and they think that they have solutions for those problems. That is why we have gone through this process and set up an external working group. HMRC, businesses and their advisers have identified issues with the current rules. We are making these changes to protect the Exchequer and reduce unfair outcomes and administrative burdens on affected businesses. The hon. Member for Ealing North referred to the worldwide debt cap.

    FINANCE (NO. 2) BILL (FIRST SITTING) · 2023-05-16 · READ IN HANSARD

  39. The measure is intended to preserve the balance between taxpayers’ rights to make double-taxation relief claims and the need to impose reasonable time limits in respect of such claims. I recommend that all of these clauses stand part of the Bill.

    FINANCE (NO. 2) BILL (SECOND SITTING) · 2023-05-16 · READ IN HANSARD

  40. Unlike normal double tax relief, which is given on tax actually paid, foreign nominal rate credit is a notional amount calculated by reference to the rate of tax applicable to the profits out of which the overseas dividends were paid. A first-tier tribunal decision in 2021 concerning the nature of this credit raised the prospect that certain claims could still be made by companies in receipt of foreign dividends prior to the introduction of distribution exemption in 2009, possibly as far back as 1973, so we needed to act. The measure will protect Exchequer revenue by preventing new claims from being made for long-settled years where no actual additional tax has been paid by the claimant. It does not seek to prevent such claims in relation to periods that are open or remain subject to ongoing litigation.

    FINANCE (NO. 2) BILL (SECOND SITTING) · 2023-05-16 · READ IN HANSARD

  41. The changes made by clause 37 and schedule 5 provide greater certainty for UK businesses, provide HMRC with better quality data to enable more efficient and targeted compliance interventions, and align the UK’s practice more closely with the transfer pricing documentation requirements of comparable tax administrations. Clause 38 makes changes to ensure that access to double taxation relief is limited in respect of dividends received by UK companies in periods prior to the introduction of a broad distribution exemption regime in 2009. Specifically, it will prevent new claims for double tax relief credit calculated at the foreign nominal rate of tax on such dividends being made on or after 20 July 2022, the date on which the Government announced in a written ministerial statement that legislation would be introduced for that purpose.

    FINANCE (NO. 2) BILL (SECOND SITTING) · 2023-05-16 · READ IN HANSARD

  42. Transfer pricing is a means of ensuring that the pricing of transactions between connected parties is at arm’s length for tax purposes. From the financial year 2016-17 to 2021-22, HMRC brought in £10 billion in additional tax from transfer pricing compliance activities. HMRC does not currently prescribe specific transfer pricing records that UK businesses must prepare to demonstrate that their tax returns are complete and accurate, or the format of those records. The proposed changes would require UK businesses to prepare OECD standardised documentation, which is described as a master file providing high-level information of the global business operations and a local file providing more detailed information about material cross-border transactions of UK group members with other members of the multinational group.

    FINANCE (NO. 2) BILL (SECOND SITTING) · 2023-05-16 · READ IN HANSARD

  43. The measure prevents the remittance basis from applying to the chargeable gain on disposal where the individual holds more than 5% of shares or securities in a UK close company and exchanges the shares for an equivalent holding in a non-UK company. Instead, the individual will pay tax as if the share exchange had not taken place. The clause will prevent tax avoidance by a small number of individuals, and protects £830 million of revenue across the scorecard period, ensuring that tax is paid on value built up in the UK on UK company securities even when securities are exchanged for securities in a non-UK company. Clause 37 and schedule 5 make changes to require large multinational businesses operating in the UK to prepare transfer pricing documentation in accordance with the OECD’s transfer pricing guidelines.

    FINANCE (NO. 2) BILL (SECOND SITTING) · 2023-05-16 · READ IN HANSARD

  44. Clause 36 makes changes to ensure that tax is paid on value built up in UK shares or securities even if the shares or securities are exchanged for an equivalent holding in a non-UK company. The measure is already legally in application since the point of its announcement in the autumn statement on 17 November last year. It will ensure that tax cannot be avoided where a UK resident non-domiciled individual with a degree of control in a UK company exchanges shares or securities in a UK close company for shares or securities in a non-UK holding company. Before the measure was introduced, individuals could claim the remittance basis on disposal of the non-UK company shares and any income received in respect of the non-UK company shares. That means that tax will be paid only on the chargeable gain or the income if it is brought into the UK.

    FINANCE (NO. 2) BILL (SECOND SITTING) · 2023-05-16 · READ IN HANSARD

  45. Abolishing the remittance basis outright would be expected to have a much more significant behavioural impact in the absence of any policy mitigations, so the headline result of the external research may underestimate the migration response.

    FINANCE (NO. 2) BILL (SECOND SITTING) · 2023-05-16 · READ IN HANSARD

  46. I think he was referring to the research published by the London School of Economics and the University of Warwick, which suggested that abolishing the non-domiciled regime would lead to very little immigration—around 0.2%. That study looked at the particular response to the 2017 reforms. As colleagues will know, several policy mitigations that were put in place in 2017 reduced the migration impact of reform: protections for non-resident trusts, the option to revalue non-UK assets at their 5 April 2017 valuation for CGT purposes and the ability to rearrange offshore investments to make it easier to bring money to the UK.

    FINANCE (NO. 2) BILL (SECOND SITTING) · 2023-05-16 · READ IN HANSARD

  47. According to the latest information, non-UK domiciled taxpayers are estimated to have been liable to pay almost £7.9 billion in UK income tax, capital gains tax and national insurance contributions in 2021, and they have invested more than £6 billion in the UK using the business investment relief scheme introduced in 2012. To put those numbers into context, £7.9 billion is just under half of what we spend on policing in England and Wales. They are extremely big numbers. When the Opposition put their plans forward, they do not address a significant risk, which we have looked into carefully. What happens if, by changing the rules and making ourselves less competitive, we start to turn away those very successful people? The hon. Member for Ilford South talked about capital flight.

    FINANCE (NO. 2) BILL (SECOND SITTING) · 2023-05-16 · READ IN HANSARD

  48. I have the great pleasure of meeting representatives of some of those industries from time to time; the excitement and the welcome they feel from the United Kingdom, partly because of the reliefs and support given by the Government, is really interesting to see. Turning to the scheme itself, we want to have a fair but internationally competitive tax system, designed to bring in talented individuals and investment that will contribute to the growth of the economy. Non-domiciled individuals pay tax on their UK income and gains in the same way as everybody else, and they pay tax on foreign income and gains when those amounts are brought into the UK. They play an important role in funding our public services through their tax contributions.

    FINANCE (NO. 2) BILL (SECOND SITTING) · 2023-05-16 · READ IN HANSARD

  49. I am delighted to answer the Opposition’s queries on non-domiciled taxpayers. Their stance is an interesting contrast to the Conservative party’s inclusive nature when it comes to wealth creation, and opening ourselves up to the rest of the world to encourage the best and brightest to come here and do business. I am interested to hear that the hon. Gentleman has something against film stars, singers and—dare I say it—movie stars who perhaps cross into the world of football. I will not name any taxpayers. But my goodness, I am sure he is proud of the fact that we have a leading film and creative industry in the United Kingdom, particularly on the outskirts of London.

    FINANCE (NO. 2) BILL (SECOND SITTING) · 2023-05-16 · READ IN HANSARD

  50. Member for City of Chester took a bit of time to talk to some of the individuals involved in the life sciences industry—that golden triangle between Cambridge, Oxford and London—she would know that what they do is genuinely inspiring. Why on earth would we not welcome people from overseas to help us in that? That little golden triangle has more tech companies in it than any place on the planet other than New York and Silicon Valley. If those places are our competitors in the tech industry, we are doing very well indeed. We want to encourage more of them to come to our country to help us to build that.

    FINANCE (NO. 2) BILL (SECOND SITTING) · 2023-05-16 · READ IN HANSARD