James Wild
MP for North West Norfolk · Conservative · United Kingdom
“I am planning to be there because I will be part of the judging panel for the champion bottled beer of Britain. It is hard work, but someone has to do it. Tomorrow, we have the Budget. UK beer duty is the second highest in Europe—nearly 12 times more than most of our European counterparts.”
House of Commons27 October 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“It is a pleasure to serve under your chairmanship, Sir Desmond. I congratulate the hon. Member for Burton and Uttoxeter (Jacob Collier) on picking up the mantle and securing this debate.”
House of Commons27 October 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Despite that, it is worth noting that smaller independent brewers are finding success in the sector—compared to some of the larger breweries that are withdrawing from the market. We heard a passionate speech from my right hon.”
House of Commons27 October 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“By taking this step of recognition, we could safeguard a living tradition that has helped shape the cultural and social life of Britain for generations. The opportunity to recognise cask ale under the UNESCO convention follows its ratification by the last Conservation Government in 2024.”
House of Commons27 October 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“As we have just celebrated Trafalgar Day, I also mention Woodforde’s Nelson’s Revenge. As CAMRA, which does so much to champion it, says, cask ale is synonymous with our great British pub.”
House of Commons27 October 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Cask ale culture has been submitted as an expression of interest, strongly backed by the 40,000 people who signed the petition and by hon. Members across the House. The Government have said that the panel is reviewing that submission. Can the Minister tell us when she expects a final decision to be taken?”
House of Commons27 October 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
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“The Minister set out that clause 100 and schedule 23 will simplify things for the introduction of the new Scottish aggregates tax, reducing the number of businesses that would otherwise need to account for the levy. That is a perfectly good and common-sense measure, so I have no further comment on it.”
House of Commons29 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Although roughly a quarter of aggregate comes from recycled sources, the overwhelming majority still comes from primary extraction. Around 90% is used by the construction industry itself. While we obviously support the principle of encouraging sustainability that is behind the levy, the construction of a single home requires, on average, around 200 tonnes of aggregate and associated materials, from the foundations to the roof tiles. At a time when the Government are looking to accelerate house building, has the Minister looked at the impact of this measure on housing delivery and cost? We will not oppose clause 99, but new clause 23 would require the Government to assess its impact on construction and infrastructure projects.”
House of Commons29 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Clause 99 will increase the aggregates levy—the tax on commercially exploited rock, sand and gravel—from April. The levy, charged per tonne of primary aggregate, is intended to encourage efficient use of materials. As colleagues will know, aggregates are fundamental to almost every form of infrastructure: they are the foundations of our roads, our concrete structures and our coastal defences. They are the essential components in so many products, from ready-mixed concrete to asphalt, lime, mortar and countless others. As the Mineral Products Association puts it so aptly, “Aggregates provide the backbone of our world”, and in the UK we use around 250 million tonnes every year. New clause 23 would require the Government to assess the impact of clause 99 on the construction industry and key national infrastructure products.”
House of Commons29 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Businesses need certainty ahead of the changes, and time to adapt their supply chains and get the relevant certification and other measures lined up. Can the Minister confirm that HMRC will be publishing detailed guidance in advance? He may tell me that it is already out there and that I have not seen it yet, but if it is not, can he assure me that it will be published in good time for those companies?”
House of Commons29 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Clause 103 excludes pre-consumer plastics, such as factory offcuts, from the definition of recycled content from April next year. The Government say that that is to ensure that the tax incentivises genuine recycling of post-consumer waste, rather than reusing scrap material. That is reasonable as it goes, but Pinsent Masons has warned that some manufacturers will no longer be able to treat their own production offcuts as recycled content. While the overall burden of tax may not have changed, the burden of liability could shift from those gaining relief through mass balance accounting to those losing relief for pre-consumer materials. The Government should be up front about who will bear the costs of the changes. Finally, clause 104 deals with commencement.”
House of Commons29 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Clause 102 allows chemically recycled plastic to count towards the 30% recycled threshold and introduces a mass balance approach. That is a welcome recognition of innovation and new technology. However, analysis from Pinsent Masons notes that it will introduce significant certification and evidential demands on manufacturers and importers, and many small and medium-sized businesses fear an extra compliance burden in the absence of clear guidance or support. Can the Minister set out to the Committee, and to those companies, what practical support the Government will provide to help businesses adapt to the new rules, and will Ministers commit to reviewing the effectiveness of the measure within a reasonable period to ensure that it is genuinely driving more recycling?”
House of Commons29 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“] It is not the Minister’s either; it is good to get that on the record. It recently reported that 21 plastics recycling and processing plants across the UK have shut down in the last two years, which is a direct result of the imbalance between export incentives, cheap virgin plastic and low-cost imports from Asia. How much additional revenue does the Treasury expect this rate increase to bring in, given that I think receipts actually fell in 2024-25? What increases in recycled content are the Government assuming will result from the measure? Has the Treasury assessed whether the costs will simply be passed on to consumers through higher prices for everyday goods? We want a tax that drives genuine behaviour change, not one that just adds to the cost of living.”
House of Commons29 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“In principle, that is reasonable, to maintain its value and sustain the incentive to recycle, but it is a practical reality that many businesses simply cannot get enough high-quality recycled plastic at reasonable prices, so raising the rate without addressing that supply constraint risks making packaging more expensive but not greener. Recycling firms are already facing higher energy bills and rising labour costs as a result of both global pressures and some of the measures that have been introduced. It is often still cheaper to import virgin or recycled plastic from Asia than to buy recycled content from within Europe, and loopholes in legislation may make it more profitable to export plastic waste than to process it here at home. The Guardian , which I confess is not my usual paper of choice— [ Interruption.”
House of Commons29 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Clauses 101 to 104 amend the plastic packaging tax introduced in 2022 to encourage the use of recycled and reduced plastic. At the end of August last year, around 5,000 businesses were registered for the tax, and 38% of plastic packaging manufactured or imported into the UK was declared as taxable under it. The tax applies to packaging with less than 30% recycled content and is charged per tonne of plastic packaging components. The Opposition believe that the Government must ensure that the policy is working effectively in practice, encouraging the industry to change and delivering genuine environmental benefit, and not simply adding cost. Clause 101 increases the packaging tax rate, this time in line with CPI, not RPI. Could the Minister explain why?”
House of Commons29 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“The hospitality and drinks sector already face a lot of pressures, so they do not need to see further increases. I therefore think that applying a retrospective 27% tax increase is a move that the Government should not take lightly. We support the principle of the industry levy and the goals that it serves, but this is concerning, and I look for some confidence from the Minister that the retrospective approach to taxation will be a one-off.”
House of Commons29 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“I wonder if he will be able to give us a bit more confidence. Will the Government commit to not applying such levels of retrospective taxation-inflation increases to other sectors? In the context of this debate about the soft drinks industry levy and the increase in it, also important is what might happen—given that the threshold and the rates have been set—if there are proposals to lower the rate to bring more soft drinks into the tax, such as milk-based drinks—the milkshake tax—coffee drinks and milk substitutes that exceed the same sugar threshold. If that happened, that would potentially be another hit to the cost of living. Industry has estimated that compliance costs could run into the tens or possibly hundreds of millions of pounds, if such an approach were taken, moving the goalposts when the policy has delivered on its aims.”
House of Commons29 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“According to research that the House of Commons Library kindly produced for me, if the Government were to take the same approach to fuel duty as they applied to the soft drinks levy—there has been a long freeze in fuel duty—fuel duty would rise by 64%, while the aggregates levy would rise by 67%. No one would defend that, so why is it acceptable in this scenario to have such an increase? Businesses make long-term decisions on investment, employment and pricing based on the stability of the tax regime. To introduce retrospective changes on this scale undermines that certainty and, I fear, risks setting a dangerous precedent. Is this now Government policy? Can the Minister rule out—as the Minister at the time failed to rule out—the Government taking a similar approach with other taxes, such as fuel duty?”
House of Commons29 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“As we have recently discussed when considering other clauses, inflation uprating is normally applied annually, not retroactively over a six-year period. When alcohol duty or fuel duty is frozen, the Treasury does not go back and seek to make up for the years it was frozen by adding them to the rate—although maybe that is what the Government are going to do—but that is precisely what the Government are now doing with the soft drinks levy. As I pointed out to the Finance Bill Committee last year, if the same backdating principle were applied elsewhere, the results would be very troubling.”
House of Commons29 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“As the British Soft Drinks Association points out, since 2015, more than 1 billion kilograms of sugar have been removed from the UK diet. Soft drinks now account for just 6% of the UK’s total sugar intake. The industry has responded to the incentives that Parliament put in place by investing heavily, innovating and reformulating on a huge scale. That is why the backdated tax rise in clause 105 is so troubling. Imposing, in one go, six years of inflation over a period when it was not imposed represents a 27% retrospective increase, something that I think—unless I am corrected by the Minister—is without precedent in recent UK fiscal policy. It is not simply a technical adjustment; it is a departure from the principles that underpin our tax system, such as clarity and predictability.”
House of Commons29 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“The soft drinks industry levy has worked in meeting its objectives, but we had a debate on it last year and, and as I warned then, we have serious concerns about the Government’s decision to backdate an inflation increase over a six-year period. That is an unprecedented move, which raises serious questions about fairness, consistency and confidence in the UK tax system. The soft drinks industry levy was introduced in 2017 by the Conservative Government to help tackle obesity, diabetes and tooth decay, particularly among children. By any reasonable measure, it has been a success. There has been a 46% reduction in sugar in fizzy drinks since the original tax came into force, and 89% of soft drinks sold now in the UK are not subject to the charge due to reformulation.”
House of Commons29 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“I am surprised that the Minister covered this important clause so briefly, as will become clear in my remarks. Clause 105 increases the soft drinks industry levy—the tax on soft drinks with added sugar, which is charged per litre, with higher rates applied to drinks containing more sugar. The Government propose to uprate the levy by combining one fifth of the CPI inflation from 2018 to 2024 and full CPI inflation between Q2 2025 and 2026. In practice, that all together means a total rise of 27%—I am surprised that the Minister did not want to get that figure on the record; it is a significant increase.”
House of Commons29 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“I welcome a response and assurance from the Minister either way on that. That said, even the institute agrees that those impacted will represent a small minority of the overall non-resident taxpayer population. We concur that this charge brings a welcome simplification to tax calculations.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“International investors might be forgiven for concluding that the Chancellor is creating a tax and regulatory environment that feels increasingly unpredictable compared with some of our international competitors. Stability and certainty matter enormously in investment decisions. [ Interruption. ] The Chartered Institute of Taxation has also raised concerns about the figures underlying this policy. The Treasury estimates in the famous tax information and impact note, which was referred to by the Minister, that fewer than 1,000 resident individuals will be affected. The institute has questioned whether that can be accurate, given what its professional members are seeing on the ground. There is particular uncertainty about whether non-resident trust taxpayers have been properly included within those calculations.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“The disregarded income regime will continue to operate, providing some limitation on the tax paid by non-residents in specific circumstances. We need to look at the clause, and the ones coming up, in the broader context. It represents a shift in how UK tax dividends flow to foreign investors and, in practice, it will effectively increase the tax rate burden on dividend recipients who are non-UK residents. At a time when the UK needs to attract international capital, we need to look at the measures in the Budget as a whole and whether they strengthen or undermine our competitive position. Attracting capital to be invested was a topic that we discussed this morning.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“As the Minister says, clause 42 abolishes the notional tax credit that non-residents have historically been able to claim on their UK dividend income. Under the current system, non-domiciled individuals can offset that notional credit against other UK income streams, such as rented income or partnership profits. However, from April, that arrangement will no longer apply. Non-residents will no longer be treated as having already paid UK tax on dividends received from UK companies, meaning that they will lose the ability to reduce their overall UK tax liability from using the credit. It is worth noting that UK residents lost access to the notional dividend tax credit back in April 2016, so in one sense the clause simply removes what is perceived as a potential unfair advantage enjoyed by non-UK residents.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“On the surface, this may look like a simple tidying-up exercise, but on closer inspection it raises some important questions about the coherence of the Government’s overall approach to taxing globally mobile individuals. While we support fair taxation, this Government have once again produced needlessly complex legislation that contains retrospective elements and leaves ordinary people potentially facing unexpected tax bills.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“The Minister has skirted over quite a few detailed issues rather briefly. It will reassure the Committee to know that I intend to take a bit more time to go through what are detailed and important principles, and to reflect on questions raised in an earlier clause—how competitive we are, what we want to do, and whether we want to attract wealthy people to the country. I will initially speak to clause 43, schedule 3 and amendments 30 to 35, which were tabled in my name. Clause 43 introduces schedule 3 of the Bill, and members of the Committee will see that the schedule runs to 14 pages of complex detail, so it is important that we properly scrutinise it. Those pages make various changes to the foreign income and gains regime brought into effect by the Finance Act 2025.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Without clear guidance, ordinary commercial transactions could inadvertently be caught. The Government must publish comprehensive examples, or businesses and individuals will be left guessing. When Ministers replaced the long-standing non-dom regime last year, they promised a clean, modern and transparent framework, yet within a year we have a schedule of corrective provisions to make the legislation operate “as intended”. That rather suggests that the original drafting was not as watertight as claimed, and that further tweaks along the lines we have suggested might still be needed before the system settles.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“It should be easier to understand and apply measures aimed at getting people to bring money back to the UK. There is a risk that, as drafted, these measures drive against the Government’s intention. Amendments 1 and 2 are tabled in a constructive spirit. Amendment 1 would stop the double counting, and amendment 2 is about the retrospective and unfair action. They would provide the certainty that, according to some experts in this field, is currently missing. Without the TRF being attractive, we will not be able to get the money coming into the country. I urge the Minister to respond more fully than she did in her opening remarks and to consider whether, on Report or at a later stage, amendments could be tabled to deliver the clarity that my amendments and those tabled by my hon. Friend the Member for Windsor offer.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“We can debate whether the number is 10,000 or 5,000, but some figures suggest that the equivalent of 750,000 basic rate taxpayers have left the country. So this is not about ideology; it is about giving certainty and addressing the points that the Bill as drafted does not. The TRF could become unusable for some because of the risks it exposes them to. There is the double taxation, which I have talked about, as well as the retrospective elements, but in addition, accusations of tax avoidance could arise from using a scheme that Parliament has itself created and lead to potentially lengthy investigations. People are leaving, and the Chartered Institute of Taxation has said that tax rules under the measure make the UK a less attractive destination for people.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Friend the Member for Windsor (Jack Rankin), relate to this issue. The Government refer to the temporary repatriation facility as encouraging wealthy people to stay and invest here, and the Treasury is counting on these measures to raise a significant sum for public services, although I note that the OBR suggests there is considerable uncertainty about that. However, we know that the wealthiest people—the wealthiest investors, the people who are supporting our entrepreneurs and the high-growth businesses that we want to see—are leaving the UK as a result of steps that the Chancellor has taken. By some estimates, 10,000 people have already got on a plane and left—those are figures from Oxford Economics.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Perhaps I could give the Committee an example to illustrate this point further: a family has an offshore trust for two adult children and one child previously used special tax rules while the other has always paid full UK tax. Under this Bill, only the first child could benefit from the TRF when the trust is wound up. That does not encourage bringing money to the UK but, I would contend, actively discourages it. Amendment 34 would therefore enable offshore trust beneficiaries who have not themselves used the remittance basis to use the TRF. Amendment 35 would enable trustees to pay a temporary repatriation facility charge on the trust’s past FIG while retaining the funds within the trust, without having to make capital payments to the beneficiary. Amendments 1 and 2, in the name of my hon.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“The temporary repatriation facility applies a 12% or 15% rate to the personal FIG of individuals who have previously used the remittance basis as well as certain capital payments from offshore trusts. This was to encourage the winding-up of foreign trust structures. Right now, though, the trusts part works only if the beneficiary getting the capital could have used the remittance basis in their own right. That creates an unfair outcome in families where one beneficiary has used the remittance basis but another has always paid full UK tax on worldwide income, because only the former can benefit from the lower temporary repatriation rate if the trust is wound up.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“That is not about closing a loophole; it is about changing the rules after people have already acted. Our amendments 31 and 32 would ensure that double taxation does not apply retrospectively. Fourthly, in this clause and schedule the Government have created arbitrary restrictions so that the TRF is available only to UK residents. Why should someone temporarily living abroad not be able to use this facility? The temporary non-residence rule means that they will be paying UK tax when they return anyway, so why not let them use the TRF? The rules create a situation where someone who wants to pay tax voluntarily is not able to do so. Our amendment 33 would ensure that the TRF is available to both UK residents and non-residents. Similar concerns have also been raised regarding offshore trusts.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Do they think it will encourage or discourage the repatriation of funds that this facility is designed to encourage, to help support our economy and public services? I would contend that the incentive, as a result, is to keep the money out of the UK, which is not what we on the Opposition side—or, I believe, on the Government side—of the Committee want to see. We therefore tabled amendment 30 to remedy this issue, and I encourage Members to support us on it when the moment comes. Thirdly, the Bill contains retrospective taxation. Let us be clear: retrospective taxation should be reserved for the most egregious tax avoidance, but here, trustees who made payments to beneficiaries in good faith after April, relying on existing law, may now face double taxation because of rules that look backwards.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“First, they believe that, as drafted, the new offshore income gains paragraph introduced here leads to an anomaly in the way that trust distributions are matched where a trust has generated offshore income gains. That results in trusts with surplus pre-6 April 2025 capital gains tax being treated differently from those without. We do not believe that to be the Government’s intention; perhaps the Minister can clarify. Secondly, investments clearly fall in value, but under this legislation, if someone invested foreign income overseas and it is now worth less, they will still pay the temporary repatriation facility charge on the original higher amount. That could mean paying 12% tax on £100,000 even though the investment is worth only £60,000. Do Committee members think that is fair?”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Part 2 relates to the temporary repatriation facility, clarifies how remittances to the UK under that temporary facility should be matched to their original source. For years, non-domiciled individuals could keep foreign money offshore, paying UK tax only if they brought it here. The TRF offers a window until 2028, precisely to encourage people to bring money to the UK at reduced rates of 12% in the next two years or 15% in ’27-28. That is, as I said to the hon. Member for Burnley, a good idea in principle, but the devil, as ever, is in the detail. Our friends at the Chartered Institute of Taxation pointed out some serious concerns that there are several paragraphs within the schedule—which I see the hon. Member turning to—that do not appear to work as intended or that produce unintended consequences.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“That is very sensible, but the Government have made claiming that relief so complicated that honest taxpayers risk falling into traps simply through lack of awareness. I hope the Government will take account of the following sensible steps suggested by the Chartered Institute of Taxation: first, to remove the requirement to report every possible element of FIG as part of the claim, and instead making relief from UK tax on FIG the default position; similarly, extending the relief to the personal representatives of a deceased individual who themselves qualified; and finally, simplifying the legislation by aligning the income tax position on trust distributions with the capital gains position. I would be grateful for the Minister’s response on those points when she winds up.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Well, indeed. I will come on to the detail. On the broader point, we support the initiative behind these measures—to encourage people to bring more of their money to the UK, precisely so it can help fund our public services. Our concern is about the implementation, and I will come on to some of the comments that representatives of the Chartered Institute of Taxation, who are widely acknowledged as experts in this area, have raised about the complexity and the retrospective elements. As I said, schedule 3 is in three parts. Part 1 relates to relief for new residents on foreign income and gains—FIG. Under the new FIG regime, when someone moves to the UK, they do not pay UK tax on their foreign income for the first four years here.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“I hope that the Minister can assure the Committee that she will look at the case for publishing clear guidance to ensure that businesses are not adversely impacted.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“The Government must provide clear, comprehensive guidance on exactly what level of review and monitoring employers are expected to undertake not to fall foul of the rules. Without that clarity and guidance, we risk creating a compliance minefield in which well-meaning employers inadvertently break rules that they could not reasonably be expected to follow. Guidance can help employers to comply with the law, as we all want them to do. The Government like to talk about making Britain the best place to do business and to champion our competitive advantage in attracting global talent—we have just discussed one area in which that may or may not be the reality—but we should seek to avoid introducing measures that potentially add to the compliance burden without giving guidance to employers.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“That sounds reasonable in practice, but I want an assurance from the Minister about the potential administrative burden that it will place on employers. It could mean that employers will now be expected to monitor the day-to-day working practices of globally mobile working employees. They will need to track whether individuals are working from home or from a hotel room in Boston, which is not necessarily a simple task. For multinational companies with hundreds of employees, this represents a potentially significant compliance burden at a time when we want to reduce the burdens on business. For smaller businesses venturing into international markets for the first time, it could be a disincentive—indeed, a barrier—to their trying to do so.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Clause 45 will extend the PAYE notification process to include treaty non-residents and introduce the 30% cap, to which the Minister referred, on overseas workday relief that can be claimed through PAYE. In simple terms, clause 45 and schedule 4 will change how employers operate PAYE for people who move to the UK but are treated as resident in another country under a tax treaty. The clause will let employers agree with HMRC that the part of the employee’s salary that is expected to be exempt overseas be left out of PAYE during the year, and it will formally limit how much foreign employment relief can be given to 30%. The changes under the clause will require employers to send further notification to HMRC whenever there is a change in the employee’s circumstances that affects the proportion of earnings subject to PAYE.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Can she guarantee that legitimate business structures that have previously been accepted by HMRC under the DPT will not suddenly fall foul of the scope of the new rules? Will she also comment on the main purpose test, to provide clarity and certainty for businesses?”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“As the Chartered Institute of Taxation rightly says, it is unsatisfactory to pass legislation with a wide definition and simply hope that HMRC guidance and rules will narrow it down later. That is not how we in Parliament should legislate. We discussed the loan charge during this morning’s sitting; HMRC applied rules in a way that most MPs did not consider reasonable, and we have now had to make changes through this Bill to address that historical issue. The law should be made clear in the Bill, not left to administrative interpretation. I would be grateful if the Minister confirmed how many multinational companies HMRC estimates are using pricing manipulation to avoid tax.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“First, the new tax design condition is very broad: it captures transactions designed to reduce, eliminate or delay UK tax liability. There is a question as to whether legitimate commercial decisions made for regulatory compliance or capital requirements could be caught by the condition simply because they are deliberate and happen to reduce tax liability, even when tax planning is not the primary motive. I know that is not the intention behind the drafting, but that point has been raised, so I hope that the Minister will respond in order to avoid any uncertainty as to whether businesses that think they are operating within the law, without seeking to reduce, eliminate or delay tax liability, may be captured. Will the existing arrangements be grandfathered? Can HMRC revisit settled positions under these broader rules?”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“In simple terms, if a global business structures its arrangements to shift profits from the UK in a pricing manipulation, HMRC will be able to bring those diverted profits into UK tax at a higher, penalty-style rate. In principle, we support that approach. Moving away from the stand-alone tax and bringing diverted profits under corporation tax provides better treaty access and clarity, and clearly the six percentage point charge works as a deterrent, as countries that play games with their transfer policies will risk paying more tax than if they had priced their UK dealings properly in the first place. However, I would welcome the Minister’s response to the concerns that the Chartered Institute of Taxation has raised about the drafting of the clause.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“The clause introduces schedule 5, which will repeal the diverted profits tax and replace it with new rules to tax unassessed transfer pricing profits within the corporation tax regime, coming into effect for periods beginning on or after 1 January. The diverted profits tax will continue to apply for prior accounting periods. In effect, the clause creates a higher tax charge on profits that should have been taxed here, but were shifted out of the UK by using non-market prices between groups. Like the DPT, the new transfer pricing profits rules are intended to target structured arrangements that are designed to erode the UK tax base by omitting profits that are subject to transfer pricing. These unassessed transfer pricing profits will be taxed at a rate that is six percentage points higher than corporation tax.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Clause 47 and schedule 6 mark an evolution in the UK’s transfer pricing regime. The Opposition recognise the importance of getting this right: it goes to the heart of how multinational profits are attributed and taxed, and therefore how we ensure that companies pay the correct amount of tax in this country. The principle behind transfer pricing is simple, even if it is rarely simple in practice. I believe that these measures flow from a consultation process launched by the last Conservative Government, so they have a good origin. I hope that they will lead to greater certainty and reduce the burden that some companies may face.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“I would add that, according to the Budget costings, the reporting duty would raise around £25 million in 2026-27, growing to £350 million a year, helping HMRC to tackle artificial profit shifting. That is welcome, but we should also consider the one-off and ongoing costs for businesses that have to re-engineer their systems. I would be grateful for the Minister’s response to my points about implementation and whether the hybrid model will actually be the best of both worlds.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“However, each new requirement—whether it is the ICTS, pillar two returns or transfer pricing documentation—adds to the cumulative impact on businesses. We need to see these obligations in the round, not as each one being reasonable on its own terms. What is the overall picture of what we are imposing on companies? If that load becomes too great, the UK will be seen as a less attractive place to invest, which is certainly not what we want. Although we support the principle of better risk assessment, we continue to press Ministers to ensure that we have proportionate and workable solutions that add value for HMRC, businesses and our constituents. New clause 4 would simply require a report setting out those impacts.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“The Treasury has said that it will consult on detailed regulations in the spring of this year. We welcome that commitment. Can the Minister give an assurance that she will make sure that businesses and representative bodies will be closely involved in shaping how the system is put into practice? With the planned 2027 start date, there is not a lot of time to get the rules in place or for companies to build or modify systems to provide the new data. Can that be done without causing undue cost and disruption to businesses? Finally, I want to make a slighter broader point on the clause. We clearly understand the importance of robust compliance and the need to protect the UK tax base on behalf of our constituents so that we can deliver public services.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“As the Minister rightly says, most major economies already have some equivalent form of reporting, but it should be pointed out that the differences between them are significant. Australia, for example, operates a single transaction-driven disclosure process through its international dealings schedule; the United States of America relies on a more fragmented, relationship-based approach spread across multiple forms. Each system clearly has its benefits and disadvantages. What matters is that each country has a clear, consistent model to which businesses can understand and readily adapt. What the Government seem to be proposing is a hybrid. That might mean that we have the best of both worlds—let us all hope so—but it might also lead to an approach that is inconsistent with the systems that some multinationals already have.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“Chasing down questions and embarking on inquiries can often lead nowhere and can cost businesses time that could be spent on growing their business. However, it is also important that the Government explain how the system will work in practice and how it will be seen to work. Our new clause 4 would therefore require a report on the impact of these changes on cross-border trade and the administrative burden on businesses. During the consultation last year, the Treasury acknowledged that more needed to be said about how the data collected through the ICTS system would be used and how it would fit alongside existing obligations such as master and local files. That remains a crucial point of detail that the industry and advisers will be looking for as this measure is implemented. Can the Minister shed some light on those concerns today?”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗
“New clause 4 stands in my name and that of my hon. Friend the Member for Wyre Forest. As the Minister says, clause 48 introduces a power for HMRC to implement a new reporting obligation: the ICTS, which will come into force in 2027. This new power would require businesses engaged in significant cross-border transactions to disclose specified information about their dealings. Rightly, the intention is to give HMRC better tools to identify transfer pricing and international tax risks that could affect the tax take, and to allow it to conduct more efficient and better-targeted compliance activity. I recognise that objective and support it in principle. I agree that the ICTS could help HMRC to identify risk earlier and to avoid wasting the time of the Department and businesses.”
House of Commons27 January 2026Contains Parliamentary information licensed under the Open Parliament Licence v3.0Source ↗