Clause 78 - Attribution of gains of non-resident companies

Finance Bill

Public Bill Committees, 3 May 2001, 10:00 am

Photo of Mr Howard Flight

Mr Howard Flight (Arundel & South Downs, Conservative)

I beg to move amendment No. 36, in page 51, line 13, leave out `tenth' and insert `quarter'.

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Dr Michael Clark (Rayleigh, Conservative)

With this it will be convenient to take the following amendments:

No. 37, in page 51, leave out lines 16 to 22 and insert—

`(b) a chargeable gain accruing on the disposal of an asset which was acquired for bona fide commercial reasons and whose acquisition or disposal does not form part of a scheme or arrangements of which the main purpose, or one of the main purposes, is avoidance of liability to income tax, capital gains tax or corporation tax,'.

No. 38, in page 51, line 37, leave out `three' and insert `six'.

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Mr Howard Flight (Arundel & South Downs, Conservative)

We return to territory that is familiar from last year's Finance Bill. At Report stage of that Bill, the Opposition thought that we had persuaded the Paymaster General to accept the reasonableness of some of our key points on the provision. The Paymaster General instituted a process of inquiry, and the measures in the clause are an endeavour to be helpful.

I wish to raise two points before addressing the amendments. First, the clause appears to apply to some important businesses that did not know about the consultation process in due time; it was over before they could have their say. Secondly, the basic point of principle is that the underlying legislation had been introduced to block a particular tax so that a certain capital gains tax avoidance scheme, which I described last year as the Belgian wheeze, could not occur. I am sure that the Government's intent is not to damage or disadvantage the bona fide commercial interests of British groups or employee trusts or charities. The amendment increases the de minimis level from 5 per cent. to 10 per cent., which is helpful, but it does not address a situation in which 60 per cent. of an overseas closed company is owned by a particular shareholder and the 10 per cent. United Kingdom shareholder has no powers. A closed company is one that is controlled by five or fewer individuals, and I assume that the Government's 10 per cent. figure was conceived as being one fifth of the 50 per cent. needed for control. However, 10 per cent. is far too low to be a significant influence; a more credible level would be 25 per cent., as in most jurisdictions the shareholder has negative control and can block special resolutions and so acquire some power of influence.

Amendment No. 37 deals with slightly different territory. The part of clause 78 to which it relates is intended to be helpful, widening the range of assets that are exempted where tangible assets, used only for the purpose of a trade outside the United Kingdom, are replaced by any asset used only for the purposes of a trade outside the UK. However, there is a problem: section 13 of the Taxation of Chargeable Gains Act 1992 is an anti-avoidance section and, as we argued last year, surely it should be expressly confined to cases of tax avoidance. The amendment is based on section 137 of the same Act, giving clearance for reconstructions or amalgamations. The form of words will be familiar in many contexts; it has been widened to cover income tax, capital gains tax or corporation tax, to mimic the words in clause 78(4). Anti-avoidance measures should be fundamentally about purpose.

The changes in clause 78 to which amendment No. 38 relates are designed to be helpful in inserting new subsection (5A) of section 13, so that when a shareholder incurs a charge on an offshore closed company he will be permitted a subsequent credit against the repatriation of the proceeds of such gains. That would give taxpayers the ability to repatriate funds to meet the tax liability, and so to avoid double taxation. The problem is that the repatriation is limited to a period within three years of the end of the accounting period in which the gain occurred, or four years from the day on which the gain itself occurred. That could result in unfairness and double taxation, because it may not be possible for some shareholders to arrange for repatriation within the three or four-year period; that harks back to the situation in which there is 60 per cent. control by another party, but the Revenue can go back six years to assess tax liabilities on taxpayers. It means that a taxpayer might be ignorant of such a liability or unable to calculate it because of genuine compliance difficulties in overseas businesses that he does not control; the time limit under new subsection (5B) could thus expire before the Inland Revenue discovered the facts and made an assessment. It would be much fairer to extend the period for credit for repatriations to shadow the period in which the Revenue can make that assessment; a six-year period should be sufficient for the United Kingdom shareholder, one way or the other, to be able to repatriate the funds from closed companies that he does not control.

10:30 am
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Mr Michael Jack (Fylde, Conservative)

I support my hon. Friend, who has given a clear and reasoned exposition. I want to discuss amendment No. 37. At the heart of the matter is the concern that closed companies might be used for tax avoidance purposes. My hon. Friend was open in referring to a possible device, but the device is visible and known about, and its purpose is understood.

My hon. Friend observed that, following last year's representations, the Inland Revenue consulted on section 13, but the consultation exercise was not distributed as widely as it should have been. One company, Grosvenor Estates, expressed interest last year, but was not directly informed about the consultation, even though it had a material interest in the substantive provision and the amendments. If that is the extent of the consultation exercise, one wonders how enthusiastic the Government were about it.

Let us focus on Grosvenor Estates, a closed company. For greater accuracy, I obtained a copy of its annual report. If one did not know that it was a closed company, one could thumb one's way through this attractively produced document and conclude that Grosvenor Estates had every characteristic of a public limited company. The company invested substantially in areas such as Liverpool, and in Preston, in my part of the world. Making profits on its capital assets at home and overseas is an essential part of its activities.

In no way could that company be described as a tax avoidance device. In common with any publicly operating company, it seeks to minimise its tax liability, but it could not be characterised as a tax avoidance vehicle especially created for that purpose. In investing in the property activities that are still the subject of this section of the tax code, such a company finds it hard to understand why it is unfairly penalised when other companies carrying out other forms of activity are relieved of having to remit capital gains tax.

During the consultation exercise—amendment No. 37 refers to it—the Revenue rejected the proposition of getting round the difficulty by having a bona fide commercial motive test. Paragraph 7 of the summary of replies to consultation states:

``The Government is not persuaded that such a test would work in this area and considers it unnecessary with the proposal that any gains on trading assets should in future be excluded from a charge under the legislation.''

Let us concentrate on the words used to justify the Government's position, as challenged by amendment No. 37.

The Paymaster General will know that motive tests apply in other parts of the tax code. If my distant memory is right, manipulations of company shares require prior approval by the Revenue under section 802—such numbers were once seared into my memory, but have become a little fuzzy round the edges with the passage of time. Companies wishing to manipulate their share capital must have the specific approval of the Revenue, so in one part of the tax code there is an element of motive test—and there may be others. Will the Paymaster General tell us in detail—if not now, later—which parts of the tax code are subject to motive tests? If they are okay in one bit of the code, why are they not okay in another?

In the criminal law of this country there is always a juxtaposition between the actions of an accused person and his motives. For example, what was in the mind of a killer plays a key part in determining whether he faces a charge of murder or manslaughter. Again, there is an inconsistency in that the Treasury rejects the possibility of a proper motive test in this context, despite the fact that a motive test is an integral part of other areas of the law. I would be the first to sign up to measures to prevent people creating artificial tax vehicles for the avoidance of tax—such as, in this context, capital gains tax—but given the entirely correct position of a company such as Grosvenor Estates, I find it hard to understand why a greater effort has not been made to resolve its problem.

I can certainly remember in my time at the Treasury seeing some quite innovative and remarkable examples of people creating artificial vehicles—but dealing with those is part and parcel of the Inland Revenue's trade. It has a team of inspectors who can spot those things. If they can spot the ne'er-do-wells, they can spot the honest Joes. I am sad that the Government were not prepared to go the extra mile to see whether they could devise a way of sorting the wheat from the chaff and being consistent in the use of motive tests.

I sometimes find it hard to understand the distinction that is drawn. I congratulate the Government on going as far as ruling out companies that are in a legitimate trade, but that raises the interesting question as to what is illegitimate about investing in property. Let us consider the case of a closed company that is set up in north America to provide machinery, such as a service company manufacturing lifts, air conditioning equipment and the like. It could decide to go into property, and acquire some substantial property assets. It might, for example, end up with a large building, part of which could be let for normal letting purposes, with the rest being used for the wholly legitimate storage of its equipment.

If it became apparent that property was becoming a major part of the company's activity, someone in the Revenue would start asking questions. By definition there would have to be an examination—almost a mini motive test—to determine whether it qualified for the tax reliefs that are part of the substantive provision. Although that is a hypothetical example, it shows that that issue will not go away if someone takes advantage of the exemption in the principle provision, but that people who are legitimately involved in a property business are caught. Amendment No. 37 seeks to relieve them.

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Mr Howard Flight (Arundel & South Downs, Conservative)

It is ironic that we have just been considering a clause that widens business relief beyond trading companies, and the argument appears to have been accepted that economically and morally there is no logic for having separate categories of tax relief. What, therefore, is the logic of arguing so strongly for separate categories in this territory?

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Mr Michael Jack (Fylde, Conservative)

My hon. Friend summarises the situation well. I shall therefore cease speaking. I look forward to hearing the Paymaster General's response.

10:45 am
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Ms Dawn Primarolo (Paymaster General, HM Treasury; Bristol South, Labour)

In discussing provisions in last year's Finance Bill, provisions that were specifically designed to prevent substantial loss of tax to the Revenue through tax avoidance, the hon. Member for Arundel and South Downs (Mr. Flight) asked me to consider several points about a possible unintended effect, particularly on charities and pension funds. He supported the principle that anti-avoidance steps should be taken and did not dispute the fact that substantial avoidance was occurring.

It is important that Committee members remember exactly what the legislation addressed. It was a targeted and proportionate measure to deal with the significant amounts of tax that we were losing. The hon. Gentleman referred to ``the Belgian wheeze'', but many other schemes were employed, all of which focused on abuse of tax treaty exemptions. They all involved companies in which trustees were participators. The rules introduced by section 94 of the Finance Act 2000 were designed to ensure that such complex arrangements involving trusts did not pay and that there was no point to them. The rules went no wider than was absolutely necessary to stop tax avoidance. In a previous debate, the hon. Member for West Dorset talked about the balance between simplicity and equity, and we talked about the cliff edge, who is caught and the fairest way to proceed. This point falls squarely into that debate.

It has been suggested that people were not aware of the consultation, but I must be firm on that. The Revenue approached everyone who raised points on last year's legislation and all the main representative bodies. It assures me that the views of anyone who had shown an interest in the subject were taken fully into account, even if they came after the stated consultation programme.

The right hon. Member for Fylde referred to Grosvenor Estates. Again, the Revenue tells me that it was in contact with the company and its advisers from the start of and throughout the consultation process. I think that I am correct in saying that we have received no further representations since the Bill's publication. Let us be clear: the amendment is designed to change an anti-avoidance provision, on which there was agreement last year. The undertaking is specifically to consider the points that the hon. Gentleman raised.

Amendment No. 36 would remove many more UK residents from the scope of the legislation at section 13. It would do so by taking out those participants with an interest of 25 per cent. or less in gain rather than the 10 per cent. that the Government propose.

The clause as drafted represents the Government's considered judgment. I understand that representative bodies believe that there should be a substantial increase; we have doubled the current limit to 10 per cent., which is substantial by any standards. We can do that without creating any new opportunities for avoidance or seriously jeopardising the tax revenues. The review has produced some refinements and some benefits. It should also bring some welcome compliance savings for investors. However, it is not right to go further; it is a matter of judgment, but an increase beyond 10 per cent. would seriously risk providing opportunities for UK residents to avoid tax on their investments.

We are not talking about what companies do and whether their activities are legitimate but about tax planning or avoidance opportunities, which we are closing off. Anyone holding an interest of 10 per cent. or more in a company has a substantial stake in it and may be able to influence its activities and there is scope for unconnected people to band together to avoid the tax charge. The hon. Member for Arundel and South Downs was correct in what he said about the normal size for a closed company; we settled on 10 per cent. rather than 25 per cent. We have given an inch but the Opposition want to take a mile, which would undermine our purpose. I ask the Committee to reject the amendment as the clause as drafted is a reasonable relaxation.

The purpose of amendment No. 37 is to replace the present exclusion for gains on assets used in overseas trade with an exclusion for gains on assets which were acquired for bona fide commercial reasons and not as part of an avoidance scheme. We covered that ground extensively in last year's debate when I made it clear why such a motive test was not appropriate in this area. Section 13 of the Taxation of Chargeable Gains Act 1992 as amended by the clause, is targeted solely on investment gains made by a non-resident, closely controlled company from which UK residents may benefit. It is absolutely right that those gains should be charged on UK residents as they arise in situations where there has been considerable avoidance activity in the past. It is right that those gains should be charged, irrespective of the motive for establishing the company. I cannot make the position clearer.

It is difficult to see how a motive test, which the hon. Gentleman is right to say exists in several parts of our tax legislation, could be made to work in this respect without rendering ineffective legislation that is tightly drawn and specifically to deal with avoidance. I am not persuaded by the arguments for such a motive test. I clearly explained the position to the Committee last year in the debate on the control of foreign companies.

The purpose of amendment No. 38—

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Mr Michael Jack (Fylde, Conservative)

For the sake of those who read the debate, and to understand where the Paymaster General is coming from, will she tell us how much tax would be at risk if the motive tests proposed in amendment No. 37 were enacted?

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Ms Dawn Primarolo (Paymaster General, HM Treasury; Bristol South, Labour)

I do not have the specific figure to hand. The anti-avoidance provisions last year resulted in substantial revenues—extremely large figures. We do not believe that a motive test is necessary. If a motive test were included, it would offer an opportunity to plan again and would completely undermine our attempts last year. Our arrangements would be nullified by the creation of different routes to avoid tax, and a similar amount of revenue would be at risk. Specifically, we are discussing a gain that should be taxed.

I know that I do not have an indication of the amount in the papers that I have with me, but if there is some way of quantifying it—I doubt it—I will let the right hon. Gentleman know. He has been robust and clear both in Committee and when he was Financial Secretary in the previous Government that avoidance is unacceptable. Anti-avoidance is a tool that the Government must use.

The purpose of amendment no. 38 is to increase the period in which the distribution of a gain can be made after the gain arises, in order for credit to be given for tax charged on the gain against the tax charged on the later distribution. The amendment seeks to increase the period from three to six years from the end of the accounting period in which the gain accrued. The amendment is another example of where we give the Opposition an inch and they want a mile.

In our view, the relaxation—it is a relaxation—that we are proposing hits the right balance. It goes further than the recommendations that were made in the Government's review. For example, the CBI—I believe that Opposition Members would accept that it is a group that represents business—suggested two years from the end of the accounting period of a non-resident company. We think that that might be a little tight in some cases and propose to take it further. To my knowledge, the only specific representation that was made about the number of years actually requested only two years; we are providing three.

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Mr Howard Flight (Arundel & South Downs, Conservative)

On the issue of time period repatriation, there is neither an avoidance nor a tax cost issue. To the extent that there is a time value of money, if people cannot repatriate their money for six years, it is worth less than after three years. The CBI made a straight from the pen suggestion. If there is a tax issue involved in the difference between three and six years, let us hear what it is. If there is not, I cannot see the point of the three-year rule.

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Ms Dawn Primarolo (Paymaster General, HM Treasury; Bristol South, Labour)

I would turn the point around on the hon. Gentleman. We write tax legislation to respond to Government policy in shaping direction and intentions. We also respond to practitioners and to the industry, where they specifically identify problems. What we do not do with tax legislation is think up a theoretical position and then write the legislation accordingly. We have consulted, points have been made to us with regard to the accounting period, and we have responded to that. The hon. Gentleman advances the case without telling us that there is a problem. It is not unreasonable for the Government and the tax authorities to work on the basis of the information supplied to us and our knowledge of operating the tax system, rather than saying, ``wouldn't it be nicer if'' and having no reason for such action. So, we have clearly consulted on the matter, we are not receiving representations, and we are not aware of specific issues in that area. Should any come to our attention, we would be prepared to consider them.

In response to the amendments, I have tried to explain the specific points that the Government sought to deal with last year. On Opposition points about consultation, we believe that there can be some relaxation, and every indication is that it is sufficient to solve the problems that were identified. Therefore I ask the Committee to reject the amendments on the basis that they would either destroy the original intent of Government legislation or make provisions that are not required. The Bill's amended provisions are a reasonable and measured response by the Government to the fair points made last year by the hon. Member for Arundel and South Downs.

11:00 am
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Mr Howard Flight (Arundel & South Downs, Conservative)

Without repeating my arguments, there is an important point of principle that it is perfectly correct and proper to take anti-avoidance measures. Equally, it is quite unreasonable of any Government or the Revenue knowingly to damage business interests where there is no avoidance. Therefore, although I congratulate the Minister on her robust defence, it strikes me that it is not entirely reasonable to have complete disregard for bona fide commercial situations that are unfairly treated as a result of robust anti-avoidance measures.

Amendment No. 38 is most important because the heart of it is that it is unfair for businesses to have to pay double taxation. If there is justification for particularly robust measures that may damage the innocent in order to stop the naughty, at least there should be a mechanism that prevents the innocent from being double-taxed.

The point lying behind the other two amendments is that, as I understand, one or two major groups are locked into minority shareholdings of between 10 and 20 per cent., where another party controls 60 per cent. Their ability to withdraw the money to pay the capital gains tax on which they are assessed is not at all self-evident or automatic. In order to be amicable, I ask the Paymaster General to consider again the three-year rule. I have consulted tax councils and do not believe that changing it would undermine the anti-avoidance measure. That is one area in which the inequity of unintentional double taxation could be prevented.

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Ms Dawn Primarolo (Paymaster General, HM Treasury; Bristol South, Labour)

Although the clause substantially extends the current period, it remains necessary to retain a reasonable time limit to ensure that relief is not given in cases in which distribution is unrelated to the gain. However, as always, we will continue to examine the issues. We need to know about the specific cases mentioned by the hon. Gentleman, in which people perceive that the rules affect them harshly. I do not expect him to tell us today, but I am sure that he would accept that it is impossible for us to be mind readers, as talented as the Government may be—if I could just get that in.

There may be cases in which representations are not being made and problems have not been identified. People may not like the fact that we have taken steps to close off the avoidance—some do not—but that is not an argument in favour of amendments to undermine the steps that we have taken. If there is no legitimate reason, we will move on and if there is, we should hear about it. We said that we would look at problems, we have contacted and consulted everyone, published the clauses and allowed for companies to comment and we do not have the responses, so I do not see what the hon. Gentleman expects of us. He may say that he expects the Government to take him at his word. As gracious as he is in Committee, I am afraid that that is not enough in this case. Serious amounts of money are at stake with regard to the anti-avoidance provision. I hope that, on reflection, he will feel that he has had an extremely wide-ranging and detailed debate this morning, and that he will not be inclined to press his amendment.

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Mr Michael Jack (Fylde, Conservative)

I thank the Paymaster General for the way in which she dealt with the debate, which has been helpful in giving us further insight into the risks that the Government see in the context of the anti-avoidance legislation. I am also grateful for her kind words about my efforts—in fairness supported by the then Opposition—to deal with serious tax avoidance.

However, for the record, I should say that it is not the Opposition's motive to undermine legitimate and proper efforts to safeguard the revenue. There are innovative, clever but sometimes misguided people out there who will try to drive a coach and horses through any chink in the tax legislation, and, ultimately, the honest taxpayers will have to pay the difference if substantial revenue disappears. The point that my hon. Friend the Member for Arundel and South Downs and I seek to tease out is that one is looking at where the shoe might pinch a little more tightly. Legitimate companies are clearly being caught by the legislation. I understand why the Paymaster General is unwilling or unhappy to go further, but if I take the tenor of her remarks correctly, perhaps the door is not completely closed on representations. If there is an opportunity to deal with the genuine concerns of those who have not so far benefited from my hon. Friend's amendments, they may have a hearing in the future.

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Mr Howard Flight (Arundel & South Downs, Conservative)

I too thank the Paymaster General for her comments. This is not the forum for exploring who is right and who is wrong in terms of adequate consultation. I will ensure that the practical case issues are brought to the attention of the Inland Revenue, especially in relation to amendment No. 38. It may well be the omission of certain parties not to have done so. On the understanding of intelligent perusal of the evidence provided, I beg to ask leave to withdraw the amendment.

Amendment, by leave, withdrawn.

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Mr Howard Flight (Arundel & South Downs, Conservative)

I beg to move amendment No. 39, in page 52, line 3, after `if', insert

`they are a trustee of a settlement for the benefit of persons named in paragraphs (a) and (b) of section 86 of the Inheritance Tax Act 1984, or'.

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Dr Michael Clark (Rayleigh, Conservative)

With this it will be convenient to take amendment No. 40, in page 52, line 3, after `if', insert

`they are a trustee of a settlement established for charitable purposes only, or'.

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Mr Howard Flight (Arundel & South Downs, Conservative)

These are partly probing amendments, particularly in the light of the Paymaster General's comments. The Government have taken the point on pension schemes and provided an exclusion but not for charities or bona fide employee trusts. Amendment No. 40 provides a definition that comes from section 86 of the Inheritance Tax Act 1984, and is clearly not a tax avoidance device for senior managers but a definition that relates to bona fide employee trusts. The probing aspect is to ask what, if any, were the anti-avoidance reasons for excluding charities and genuine employee trusts. If there were no good reasons, the amendment should be accepted prima facie because it is incorrect and unreasonable to exclude pension funds but not charities and genuine employee trusts.

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Ms Dawn Primarolo (Paymaster General, HM Treasury; Bristol South, Labour)

I will respond briefly to the amendments and ask the Committee to reject them if the hon. Gentleman wishes to press them to a Division. Both amendments deal specifically with the points that he raised last year on charities and pension funds. I am sure that he will agree that the relaxation that we introduced will go some way to addressing points made, for example by the right hon. Member for Fylde, about backseat partnerships and several other issues. We must examine the range of provisions to see why the amendments will suffer the same fate as previous amendments moved by the hon. Gentleman.

The consultation produced no cases to demonstrate that there were particular problems in the matter. Amendment No. 40 would exempt charities from the capital gains tax anti-avoidance provisions, but a letter from the Institute of Chartered Accountants of Scotland, which was sent to us after we had contacted everyone involved, said that it had trawled its members and discovered no relevant cases. The hon. Member for Arundel and South Downs believes that there might be a problem, but the charities are telling us that there will not.

There is one exception. It has been drawn to my attention that a small charity sent an e-mail last night, which queried an element in the provisions.

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Ms Dawn Primarolo (Paymaster General, HM Treasury; Bristol South, Labour)

I was going to ask the hon. Gentleman if he was acting under an alias.

Therefore, I cannot say that we have had no representations about the issue and, as such, that the amendments are unnecessary. We must examine the e-mail, but we still firmly believe that the problem raised by the hon. Gentleman does not exist. We are supported by the fact that no one, with the exception of that one late submission, is asking us to change the clause. The Revenue, as a reasonable agency, will consider those points; the charity might only need clarification. Therefore I reject these amendments, too. I now need to know what was the problem raised in the e-mail that we received last night.

To conclude, I assure the hon. Gentleman that it is not our intention to target bona fide charities, so amendments Nos. 39 and 40 are not necessary. I hope that he is satisfied that we have thoroughly considered what he said—even to the point of acknowledging that an e-mail that arrived the previous evening can be considered and responded to.

11:15 am
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Mr Howard Flight (Arundel & South Downs, Conservative)

Yet again, I thank the Paymaster General for the thoroughness of her consideration of the matter. I also repeat the comment that I made from a sedentary position—that the charity concerned has nothing to do with me. I know nothing about it.

I want the Paymaster General to clarify a simple point, to which there are two possible responses. One is that there are no known case studies of charities or genuine employee trusts that hold investments that could lead to their being unfairly taxed. The other is that the legislation as drafted at present would prevent them from being unfairly taxed in such circumstances. What is the Paymaster General's opinion?

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Ms Dawn Primarolo (Paymaster General, HM Treasury; Bristol South, Labour)

Apart from that e-mail, we have not received any indications of difficulties. Why would we want to change the legislation, when we do not have a problem with it? The organisations concerned do not believe that they are being unfairly treated, and the clause as it stands is targeted to meet their requirements.

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Mr Howard Flight (Arundel & South Downs, Conservative)

It seems to me that there is still an argument that a charity does not pay capital gains tax, so the legislation would not apply to it. I am unsure whether the Minister is proposing that argument, or simply saying that she does not know of any charities that happen to have invested in closed companies. There is an important difference between those two positions.

With regard to the amendments, the Paymaster General has made the point that before the legislation reaches the statute book the Revenue will now pursue the question of whether there will be problems for charities. On the basis of her comments, I beg to ask leave to withdraw the amendment.

Amendment, by leave, withdrawn.

Clause 78 ordered to stand part of the Bill.

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Mr Graham Allen (Government Whip (technically Vice Chamberlain, HM Household); Nottingham North, Labour)

We are doing well with regard to the programme motion and we have already covered the business that was designed for our afternoon sitting. I have discussed the matter informally with Committee members from all parties, and I found no go great desire among them to meet this afternoon—[Interruption.] Was there some objection to that? No? I think, therefore, that the appropriate form of words would be that the Committee, at its rising this morning, should adjourn till Tuesday next at 10.30 am.

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Dr Michael Clark (Rayleigh, Conservative)

Will the hon. Gentleman move that formally?

Further consideration adjourned.—[Mr. Allen.]

Bill to be further considered on Tuesday next at half-past Ten o'clock.—[Mr. Allen.]

Adjourned accordingly at nineteen minutes past Eleven o'clock till Tuesday 8 May at half-past Ten o'clock.