Clause 78 - Attribution of gains of non-resident companies
Finance Bill
11:00 am
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.