Schedule 6
Finance (No. 2) Bill
5:00 pm
Mark Hoban (Shadow Minister, Treasury; Fareham, Conservative)
I am not going to go into that because it distracts from our purpose. A problem I have detected with our adumbrations is that sometimes too much detail gets in the way of the thrust. It is important for those outside this debate to have their minds focused on the essence of the argument, rather than be distracted by the hon. Member for Wolverhampton, South-West (Rob Marris) down the highways and byways of the voluminous legislation that underpins our proceedings today.
That deals with section 209. [Interruption.] Letme come back to the second issue, where the sub-participation is to a connected party. There are some issues around the timing of interest payments and whether that is a timing difference, and there are some issues around transfer payments, but in the view of the Chartered Institute of Taxation that is neither here nor there. However, there is a concern that where a connected party is involved there may be no relief available for impairments due to the denial of connected party impairments. Its belief is that in the original drafting this appears to be unintentional; I would be grateful if the Paymaster General were to confirm that that is indeed the case—or that her Government amendments Nos. 66 to 70 address this concern.