(Except clauses 11, 18, 40, 43, 44 and 69 and schedule 8) - Clause 24 - Deduction cases
Finance Bill
2:45 pm
Dawn Primarolo (Paymaster General, HM Treasury; Bristol South, Labour)
That point does not stand up; it is totally illogical. If that were the case, why would schemes be sold at exorbitant cost and be on the market? If companies structure themselves in such ways, they will reduce their taxes.
I will not start giving tax advice to multinationals in this Committee or discussing complicated financial structures. The information comes from disclosure; the consultation on the guidance notes has been quite clear; and the examples in the guidance notes have also been consulted on. The companies that I have met have concerns about the operation of the rules—some of which we have addressed and others that we will deal with during the course of discussion—as they always do with new procedure. However, a number of those companies have accepted that there are issues and it is right for the Government to act on that basis.
There is no need for the hon. Gentleman's amendment. The overlap between different anti-avoidance rules is commonplace and is generally a good thing, because it stops transactions deliberately taking advantage of the unintended gaps. In practice, the overlap does not lead to problems. That is not just the experience of the UK tax authorities, but is common practice in those of the industrialised economies.