Lucy Rigby
MP for Northampton North · Labour · United Kingdom
“Border communities rely on strong transport links, and my hon. Friend is a strong advocate for the interests of his constituency and those in the surrounding area. The Government are delivering for people in all parts of the UK, including investments that will benefit those on both sides of the English-Welsh border.”
“Nothing was snuck out. A third runway at Heathrow means more than 60,000 good local jobs, and more than £40 billion for the British economy. The hon. Lady’s question rather highlights the Lib Dems’ curious approach to growth.”
“My right hon. Friend the Member for Makerfield (Andy Burnham) will speak for himself, but I am confident that his view is that growth extends far beyond the area that the hon. Gentleman referred to.”
“Effective transport links are vital to the prosperity and wellbeing of people across the country, including in our border communities. We have been working closely with the Welsh Government to deliver a plan for Welsh rail, and we continue to work with devolved Governments to ensure that border communities stay connected.”
“We have been clear that Heathrow expansion needs to benefit everyone, not just London. The Department for Transport has shown that expansion would deliver UK-wide support for trade, with 40% of the estimated GDP benefits from expansion being outside London and the south-east.”
“The Pride in Place programme provides £5.8 billion of support to 284 neighbourhoods right across the country, including five places in my hon. Friend’s constituency, which she does so much to advocate for. We will set out more details of further funding in the Budget.”
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“The clause also gives the Government the power to amend the penalties by regulation in future. I commend clauses 259 to 262 to the Committee.”
“That ensures that the consequences of not paying income tax or capital gains tax by the statutory due date are fair and consistent. Clause 262 will increase the penalties for taxpayers who are late in filing their corporation tax return for the first time since 1998, as part of the Government’s work to close the tax gap and make more money available to fund vital public services. Specifically, clause 262 will increase the flat-rate penalty for a company that fails to file its company tax return on time from £100 to £200. If the return is more than three months late, the flat-rate penalty of £200 will increase to £400, replacing the initial penalty. If there are three successive failures, the flat-rate penalties of £500 and £1,000 will be increased to £1,000 and £2,000 respectively.”
“The late submission penalty regime already offers leniency for those occasionally submitting late, as they would receive a penalty point, rather than an immediate financial penalty. Customers who believe that they should not be in self-assessment should contact HMRC as soon as possible, so that they can be taken out of the system and avoid any unnecessary penalties. A question was raised about when lower income taxpayers will move into the system: it will apply to all taxpayers in IT self-assessment from the 2027-28 tax year. Clause 261 makes technical changes to ensure that HMRC is consistent when penalising late payment of amounts due, following the decision of a tribunal. It will enable a late payment penalty to be charged in the circumstances I have just described.”
“He is right to say that moving to a points-based system is better: it ensures that those who make the occasional mistake do not face financial penalties, while those who persistently fail to meet obligations will still face them. Late payment penalties are more proportionate to the amount of tax owed and the time taken to pay. Amendment 50, as the shadow Exchequer Secretary outlined, seeks to stop customers being penalised for late filing, even if they do not have a tax liability. We reject that amendment. The late submission penalty regime is intended to underpin the legal obligation to submit returns on time, whether there is tax to be paid or not, and amendment 50 is entirely contrary to that intention. The tax return helps HMRC to administer the tax system effectively, and to protect the Exchequer from error and fraud.”
“I will speak to clauses 259 to 262 in brief terms, and I will then speak to amendment 50. The clauses make changes to ensure that penalties are fairer and more proportionate across the tax system. They also make sure that HMRC is consistent when penalising late payment of amounts due, following the decision of a tribunal, and increase the penalties for taxpayers who are late in filing their corporation tax return. I welcome the shadow Exchequer Secretary’s support for these changes. He points out the unfairness now, but I gently say to him that the Conservatives did nothing to change the system to make it fairer during the 14 years that they had the opportunity to do so.”
“Clause 267 will ensure that HMRC can request information from customers; it sets out the potential consequences of a clearance being revoked. Clause 268 will allow HMRC to revoke an advance tax clearance and charge a penalty in circumstances in which false or misleading information has been provided. Clause 269 will allow HMRC to publish notices governing the administration of the service. Clause 270 sets out that the Government may make adjustments by statutory instrument to ensure the effective functioning of the service. Finally, clause 271 sets out and defines certain terms used in the advance tax clearance provision. I commend the clauses to the Committee.”
“The clause confirms that the person undertaking the project, or a person who controls the project, such as a consortium member, joint venture partner or partner in a partnership that shares control, qualifies as an applicant. Clause 264 sets out the extent to which HMRC is bound to maintain the tax treatment agreed in the clearance for five years, unless material facts change. I should point out that the clearance will not be binding on the customer. The clause binds HMRC against changing its interpretation of the law, but not against a change in case law or the will of Parliament by changes in legislation. Clause 265 simply provides for advance tax clearances issued by HMRC to be extended past the initial five-year period. Clause 266 will provide for modification or revocation of an advance tax clearance issued by HMRC.”
“These clauses introduce the advance tax certainty service for major investment projects, which will be launched in July 2026. The service will provide a binding decision on how the UK’s tax rules will apply to a project before material investment has taken place. Clause 263 will give HMRC the power to issue decisions, known as clearances, about how corporation tax, VAT, stamp duty, PAYE and the construction industry scheme will apply to investors undertaking large investment projects in the UK. The threshold for investors to be accepted into the service is expenditure of £1 billion in the UK over the lifetime of a project.”
“Clause 263 accordingly ordered to stand part of the Bill. Clause s 264 to 271 ordered to stand part of the Bill. Clause 272 Cryptoasset reporting: users and controlling persons resident in the UK Question proposed, That the clause stand part of the Bill.”
“The impetus behind the series of changes made by these clauses is to implement the corporate tax road map, as the shadow Exchequer Secretary recognises, with the aim of supporting inward investment and helping investors to invest in the UK with confidence. As for the £1 billion threshold, the Government will assess the performance of the service when it has been in operation for one year and will consider lowering the threshold as part of that review. To answer the remainder of the shadow Exchequer Secretary’s questions directly, there is no limit on the number of extensions that can be sought or granted. Once again, he will be thrilled to know that—as is so often my answer to his questions—there is already draft guidance on gov.uk to add to the draft guidance that he has committed to reading this evening. Question put and agreed to.”
“Clause 273 is a maintenance provision for clause 272 that allows the Treasury to lay further secondary legislation, if required, to maintain the domestic reporting legislation under the reporting framework. The clauses legislate to provide HMRC with reporting framework information on UK-resident customers reported by UK cryptoasset businesses, which will streamline reporting. I therefore commend the clauses to the Committee.”
“Clauses 272 and 273 will make changes to ensure that HMRC receives information under the cryptoasset reporting framework from UK cryptoasset businesses about their UK-resident customers. This will streamline reporting for businesses, which will be able to use the same HMRC reporting portal for both their UK and non-UK resident customers. The changes made by clause 272 will require UK cryptoasset businesses to report data about their UK customers to HMRC in a consistent manner. That will streamline reporting and ensure that HMRC will have standardised data on all UK taxpayers in countries, including the UK, that have implemented the cryptoasset reporting framework. That data will consist of details of the taxpayer and aggregated data concerning their transactions involving cryptoassets.”
“If they do, they will be reported under the common standard; if they do not, they will be reportable under the reporting framework. Clarification on these matters has been reflected in HMRC guidance and stems from the OECD FAQs on this area. I could talk about the extent to which tokenised financial products need to be reported under CARF, a position of which those involved with traditional financial products—TradFi, as I believe they are called by those in the game—have been aware for some time. We have engaged extensively with industry and with the OECD on the subject, and this has been reflected in HMRC guidance. Q uestion put and agreed to. Clause 272 accordingly ordered to stand part of the Bill. Clause 273 ordered to stand part of the Bill.”
“I welcome the shadow EST’s interest in these matters. The DL Committee debate to which he referred was indeed an interesting one. [Hon. Members: “Hear, hear!”] I am glad that other Members agree. The matters that the hon. Member and I discussed in that debate included the Financial Conduct Authority’s supervisory powers vis-à-vis qualifying cryptoassets and indeed the definition of qualifying stablecoin. The matters addressed by the clauses are slightly different. I can speak to the definitions, but this is a slightly different context: it is about CARF, the cryptoasset reporting framework. Stablecoins are cryptoassets for the purposes of the legislation. They can be a specified electronic money product: they would meet that definition if they meet the criteria set out in the legislation.”
“Innovation is a key driver of long-term economic growth, higher productivity and improved living standards. That is why this Government are investing more in R&D and why we are committed to maintaining the generosity of R&D tax reliefs. We remain open to new and innovative debt instruments and we review options regularly, but clearly new instruments need to meet a range of criteria, including value for money.”
“I am grateful to the hon. Member for his question. Indeed, he and I have discussed this issue previously. We are due to meet to discuss it later this month, and I am very much looking forward to that discussion.”
“My hon. Friend raises an important point. This Government are investing an extra £29 billion in our national health service. I would be happy to meet him to discuss it further.”
“Member for Maidenhead to withdraw new clause 28. In any event, it should be rejected. New clause 29 asks the Chancellor to lay a report before the House within the next 12 months assessing the impact on small and medium-sized enterprises of the changes made under clause 35. The Government monitor the impact of all changes made to existing tax reliefs. However, publishing a report on the change introduced by clause 35 within the next 12 months would not be reasonable as the first full tax year of these changes is the tax year 2026-27, so HMRC will not have complete information to assess their impact. New clause 29 should therefore be rejected. In addition to rejecting new clauses 28 and 29, I commend clause 35 to the Committee.”
“Turning to the non-Government amendments, new clause 28 asks His Majesty’s Revenue and Customs to assess the potential benefits of establishing a digital application process for taxpayers seeking to pay capital gains tax by instalments following disposals to employee ownership trusts. The facility to pay CGT in instalments is a long-standing feature of the tax code and is well understood by both taxpayers and HMRC. The process for applying to pay by instalments is clearly set out within HMRC guidance and applications are dealt with swiftly once they have been received by HMRC. My officials have met representatives from the employee ownership sector to provide bespoke guidance on how these instalment payment provisions apply to disposals to EOTs. That engagement continues. I therefore ask the hon.”
“Importantly, the Employee Ownership Association has stated that the changes we are making are not such as to alter the fundamental strength and purpose of the employee ownership trust model, while also recognising that the previous level of relief, or the level of relief as it stands, was hard to sustain when set against the rapidly escalating fiscal cost. On the comments made by the Liberal Democrat spokesman, the hon. Member for Maidenhead, I set out the reasons why we reject new clauses 28 and 29. I maintain the position of rejecting those and maintaining clause 35 as it stands. Question put and agreed to. Clause 35 accordingly ordered to stand part of the Bill. Clause 36 Anti-avoidance: collective investment scheme reconstructions Question proposed , That the clause stand part of the Bill.”
“To the comments from the shadow Minister, the hon. Member for Wyre Forest, it is important to bear in mind that on the changes we are making to EOTs, even post these changes, the relief that will be on offer remains more generous than for many other options and deeds, such as business asset disposal relief. Of course, the fiscal climate is relevant to the changes we are making. He referred to the point at which the last Government introduced this relief, but as I said, the cost of the relief as a whole is projected to rise to £2 billion by 2029-30 without the action that we are taking. As I said, the fiscal climate is extremely relevant when looking at £2 billion of relief.”
“The amendments introduced by the clauses will allow HMRC to address situations where arrangements have been added to otherwise commercial transactions that reduce or eliminate, rather than just defer, a tax charge, allowing them to be more effectively challenged. The rule has been updated so that it affects only the shareholders who benefit directly from the avoidance. Where HMRC agrees that there is no avoidance and the reorganisation is carried out within 60 days of the Budget announcement or if HMRC’s decision is later, the current legislation will apply. For those reasons I commend clauses 36 to 38 to the Committee.”
“Clauses 36 to 38 make changes to the CGT anti-avoidance provisions that apply to company share exchanges and reconstructions, or the reconstruction rules, as they are known. Clause 36 revises the collective investment scheme reconstruction anti-avoidance rule to align with modern provisions with a similar purpose. Clause 37 revises the share exchanges and company reconstruction anti-avoidance rule to align with modern provisions with a similar purpose, too. Clause 38 does exactly the same. The changes made by these clauses, which take effect from Budget day, modernise the anti-avoidance rule so that it focuses directly on arrangements where the purpose, or one of the purposes, is the avoidance of tax.”
“Clause 36 accordingly ordered to stand part of the Bill. Clauses 37 and 38 ordered to stand part of the Bill. Clause 39 Incorporation relief: requirement to claim Question proposed, That the clause stand part of the Bill.”
“I welcome the support that was expressed, on the whole, by the shadow Economic Secretary to the Treasury. I suspect that that support is born from a recognition that we really do need to make the changes. Recent court decisions have shown that the rules as they stand, which date back to the ’70s, do not work as intended, especially when the avoidance carried out is a smaller part of a larger commercial reconstruction. The main effect of the rules will be to discourage the minority—and it is very much a minority—who would otherwise seek to avoid tax. It is about protecting our tax base from abuse for the benefit of the majority of taxpayers who apply the rules correctly. For those reasons, I truly believe that the clauses strengthen the protection against avoidance and will catch tax avoiders. Question put and agreed to .”
“Clause 39 makes a change to incorporation relief for CGT, requiring taxpayers to make a claim for relief and, as a result, improving the data available to HMRC to undertake analysis and compliance activity. Specifically, the change will mean that taxpayers need to make a claim for incorporation relief on their self-assessment return. That will apply to transfers of a business on or after 6 April 2026, and it will allow HMRC to monitor the relief and tackle avoidance more effectively, protecting revenue and helping to close the tax gap, with an additional £225 million expected to be collected over the scorecard period.”
“While it is important to be clear about the fact that the additional data is being collected, the details required from taxpayers are brief, and that goes to the question of the additional burden or, indeed, lack thereof. They are brief details of the type of business, the tax calculations for the assets disposed of, and the value of the shares received for the business. The information HMRC requests will be used in analysis and compliance activity, which will tackle abuse of this relief for the benefit of the majority of taxpayers who apply the rules correctly. The point on awareness was fairly raised. I can confirm that new guidance will be provided alongside the self-assessment return. Question put and agreed to. Clause 39 accordingly ordered to stand part of the Bill.”
“The effect of the changes made by clause 41 is that investors are not required to make or deliver a return in order to claim relief in respect of a particular disposal. In fact, the clause reduces administrative burdens by clarifying when non-resident companies and individuals have to notify HMRC of a disposal. I therefore commend these clauses to the Committee.”
“Clauses 40 and 41 make various changes to the capital gains rules that apply to disposals of UK land and property by non-UK resident persons. Turning first to clause 40, the changes that are being made have been in effect since Budget day and ensure that, for the purposes of the non-resident capital gains legislation, each cell in a cell company is looked at individually for the purposes of the property richness rules. That will prevent the use and ongoing exploitation of such entities to avoid the non-resident capital gains rules and will protect the tax base. Clause 41 makes changes to the rules for non-resident capital gains in respect of double taxation treaties and the requirement to claim double taxation relief, and it also clarifies some unclear terminology.”
“Clause 41 ordered to stand part of the Bill. Clause 42 Abolition of notional tax credit on distributions received by non-UK residents Question proposed, That the clause stand part of the Bill.”
“I welcome the “hurrah” from the shadow Minister. On his latter point about double taxation treaties, as he will know, many of the agreements were negotiated before the introduction of the non-resident capital gains regime. As treaties come up for renegotiation, as they do, or as we negotiate new treaties, we will seek to include a provision in the capital gains article to allow the UK to exercise our domestic taxing provisions in full. On the shadow Minister’s point about cell companies and the extent to which they are used to avoid tax, there is anecdotal evidence that such structures have been created to help individuals avoid paying tax on gains made through the disposal of UK land and property, and the changes to the rules seek to cure that. Question put and agreed to. Clause 40 accordingly ordered to stand part of the Bill.”
“Clause 42 abolishes the notional tax credit available to non-UK residents on UK company dividends. That credit no longer serves a purpose, under the modern dividend taxation system, and the change brings non-UK residents in line with UK residents, who do not receive the notional tax credit. It will impact fewer than 1,000 non-UK resident individuals who have UK dividend income and other UK income, such as property or partnership income, a year. The clause removes the outdated notional tax credit for non-UK residents receiving UK dividends, aligning their position with that of UK residents. I commend the clause to the Committee.”
“The shadow Minister is right to refer to my earlier figure that fewer than 1,000 non-resident individuals have taxable UK income in addition to their UK dividends, and that remains the figure that we are working with. Question put and agreed to. Clause 42 accordingly ordered to stand part of the Bill. Clause 43 Non-resident, and previously non-domiciled individuals Question proposed, That the clause stand part of the Bill.”
“Again, I welcome the shadow Minister’s support for these measures. However, he is absolutely wrong to suggest that these measures and the broader package will discourage foreign investment in UK companies. He will have heard the titter of laughter when he talked about the importance of stability—that not being something that was provided by his party at all when it was in government. The removal of the notional tax credit will not discourage foreign investment in UK companies, as it will not impact the overwhelming majority of overseas investors who remain outside the scope of UK tax. In order to be affected by the measure, overseas investors will also need to have other taxable UK income, typically rental income or partnership income. If they do not have that, their dividends will not be taxable in the UK while they remain overseas.”
“Clause 44 makes minor amendments to the residence-based tax regime, as introduced in the Finance Act 2025, to ensure that tax-free or exempt income is taken into account correctly under the settlements and transfer of assets abroad matching rules. The clause ensures that the internationally competitive residence-based tax regime operates as intended in relation to foreign income and gains from non-resident trusts and similar structures.”
“Clause 43 makes amendments to the residence-based tax regime that was introduced in the Finance Act 2025. These changes reflect feedback from the Government’s continued engagement with stakeholders to make sure that the regime works as well as possible. Clause 43 and schedule 3 consist of three parts. Part 1 of the schedule makes minor corrections to the foreign income and gains regime and to legislation connected with the ending of the remittance basis. Part 2 of the schedule makes technical amendments to the legislation for the temporary repatriation facility. Part 3 of the schedule amends the temporary non-residence rules by removing the concept of post-departure trade profits from legislation.”
“I have a note on that somewhere, so I will come back to it. I will deal first with the suggestion that restrictions on the TRF are arbitrary. The position of someone who is temporarily abroad arose. The TRF is designed to encourage people to be UK-resident and bring funds into the UK economy. Allowing non-residents to use the TRF would let individuals benefit from the reduced charge without living here or contributing to the UK economy, which would reduce the incentive to become or remain UK-resident. As I said, I reject amendment 1 because there are already measures in place that prevent double counting. I have dealt with amendment 2. I want to deal with the reporting of every element of FIG, which I have a note on, as I said. [ Interruption. ] That is the wrong note. I will have to come back to that.”
“Replacing the outdated remittance basis is sensible, and the temporary repatriation facility offers a helpful transition. Another criticism is retrospection. In this instance, the Government feel that a retrospective change is a proportionate response to protect revenue, which, as the hon. Member for Mid Bedfordshire said, is essential for public services. This change will prevent taxpayers from benefiting from unintended windfalls and promotes consistency in the application of rules, bringing the capital gains position into line with the income tax provision. In most cases, trusts will not yet have made capital distributions, meaning that beneficiaries and trustees will have advance notice and can plan their affairs. A further topic that that came up is the reporting of every element of FIG.”
“A criticism of complexity has been made. The aim of these reforms is, of course, simplicity. I think it is recognised across the House that in matters of taxation, simplicity is better. We are ensuring that the legislation works as it is intended to do. The shadow Minister, the hon. Member for North West Norfolk, referred to the Chartered Institute of Taxation. It is important to note this quote from the institute: “Moving from domicile to residence as the basis for taxing people who are internationally mobile makes sense.” As well as being a major simplification, it is a fairer and more transparent basis for determining UK tax. Residence is determined by criteria far more objective and certain than the subjective concept of domicile.”
“I am grateful to my hon. Friend for his intervention. I think it is right to say that the reporting of every element of FIG will not be necessary. I am afraid I shall have to confirm in writing exactly why that is the case. Question put and agreed to. Clause 43 accordingly ordered to stand part of the Bill . Schedule 3 Non-resident, and previously non-domiciled individuals Amendment proposed : 30, in schedule 3, page 271, line 26, leave out from “amount” to end and insert “is the lower of— (a) the value of the amount when it first arose to the individual, or (b) its value on 6 April 2025.”— (James Wild.) This amendment provides that where an investment derived from foreign income has fallen in value, the temporary repatriation facility (TRF) charge is paid on the reduced value of the investment at the point the TRF opened.”
“We will also specify that if the employer’s best estimate of qualifying employment income for an employee eligible for overseas workday relief is more than 30%, it must be limited to 30%. That should ensure that in most cases the provisional overseas workday relief received in-year does not exceed the relief that the employee can claim when they file their tax return. These changes will place the treatment of treaty non-residents on a statutory basis, prevent excessive in-year provisional overseas workday relief and ensure that the PAYE legislation operates as intended. I commend clause 45 and schedule 4 to the Committee.”
“Clause 45 and schedule 4 will make changes to the pay-as-you-earn notification process that enables employers to give provisional in-year tax relief to globally mobile employees, including those eligible to claim overseas workday relief. The majority of changes made by the clause and schedule are minor, technical changes that will help the legislation relating to the PAYE notification process to operate as originally intended, but a few are more substantial. For example, treaty non-resident employees—that is to say, UK residents who are covered by a double taxation agreement between the UK and another country—have been permitted to benefit from provisional in-year tax relief by concession, so they are now being added to the legislation to formalise that treatment.”
“I can confirm that guidance will be forthcoming, and I am absolutely sure that it will be clear. I am also pleased to confirm that there will be no additional administrative burden on employers, because employers already have to enter a percentage figure on the PAYE notification form; as I say, this change will just require them to limit the in-year relief provided to no more than 30%. The guidance will be given to employers in April when the changes go live. Question put and agreed to. Clause 45 accordingly ordered to stand part of the Bill. Schedule 4 agreed to. Clause 46 Unassessed transfer pricing profits Question proposed, That the clause stand part of the Bill.”
“Clause 46 will introduce a new corporation tax assessing provision for unassessed transfer pricing profits. It will replace the diverted profits tax, a stand-alone tax that will be repealed in its entirety, providing a significant simplification. The changes made by the clause will make the rules clearer and more straightforward for businesses to implement, and will support access to treaty benefits, including relief from double taxation under the mutual agreement procedure. The removal of the diverted profits tax as a stand-alone tax is a very significant simplification, and bringing the rules into the corporation tax framework will clarify the interaction with transfer pricing and access to treaty benefits. I therefore commend clause 46 and schedule 5 to the Committee.”
“I hope that what I am about to say will provide a good deal of reassurance to the shadow Minister. The purpose of the reform was to simplify the legislation and bring the regime into the corporation tax framework. There is no intention at all to change the scope of the regime. I appreciate that the question as to when the reforms will come into effect is of some importance. I can confirm that they will take effect for chargeable periods beginning on or after 1 January 2026. For prior periods, the diverted profits tax will continue to apply. The shadow Minister asked how many companies would be affected. I am afraid that I do not have the statistics to hand, but I can investigate and confirm them to him in writing. Question put and agreed to. Clause 46 accordingly ordered to stand part of the Bill. Schedule 5 agreed to.”
“The changes made by the clause will update UK law in line with international standards, will reduce compliance obligations and will address areas of potential legislative weakness. I commend clause 47, schedule 6 and Government amendment 20 to the Committee.”
“Clause 47 will simplify the UK’s transfer pricing rules, which protect our tax base by ensuring that transactions between UK companies and related parties are priced appropriately. The changes made by the clause include the general repeal of UK-to-UK transfer pricing where there is no risk of tax loss. This will provide a meaningful simplification for businesses. Alongside it, amendments have been made to the participation condition, intangibles, commissioners’ sanctions, interpretation in accordance with OECD principles, and financial transactions. Government amendment 20 will ensure the consistent use of terminology with respect to financial transactions throughout the legislation.”
“I confirm that the shadow Minister is right about the origin of the proposals and the date of the consultation. It is entirely right that we are bringing UK transfer pricing legislation up to date; it was last materially updated in 2004, so it is high time that these rules were updated. Question put and agreed to. Clause 47 accordingly ordered to stand part of the Bill. Schedule 6 Transfer pricing Amendment made: 20, in schedule 6, page 318, line 41, at end insert— “(ba) in subsection (4)(b), for ‘issuing company’, in both places it occurs, substitute ‘borrower’,”.— (Lucy Rigby.) The amendment deals with a missing consequential change to section 154 of the Taxation (International and Other Provisions) Act 2010 (transfer pricing). Schedule 6, as amended, agreed to.”
“Most major economies have similar requirements, and we do not expect the international controlled transactions schedule to have a significant impact on cross-border trade. Rather, this measure is expected to improve fairness, ensuring that multinational enterprises pay tax on profits generated from economic activity in the UK. It is also expected to increase efficiency, meaning that HMRC compliance activity can be more effectively targeted, benefiting compliant taxpayers. I urge the Committee to reject new clause 4.”
“Clause 48 will create a power for the commissioners of HMRC to issue regulations requiring certain taxpayers to file an international controlled transactions schedule. This measure is expected to have an impact on approximately 75,000 businesses within the scope of the UK’s transfer pricing and related rules. Most of these businesses are part of large multinational groups. New clause 4 would include a requirement for the Chancellor to lay a report before the House of Commons, within six months of the Act being passed, on the impact of the implementation of clause 48 on cross-border trade and administrative burdens on business. It asks that the report focus on Government steps to consult affected businesses.”