Clause 31 - Commencement
Finance Bill
10:30 am

Dawn Primarolo (Paymaster General, HM Treasury; Bristol South, Labour)
As the hon. Gentleman says, the clause deals with the commencement of the arbitrage rules in relation to both deduction and receipts cases. Provisions in any Finance Bill often take effect from the date of Royal Assent, thereby giving companies time to take them on board. However, in common with most anti-avoidance legislation, the relevant clauses have a Budget day start—in this case, 16 March 2005. The reasons for that are obvious; a Budget day start date removes the opportunity for companies to exploit any identified gap between the announcement and the commencement of the new rules. Allowing a gap between those dates could lead to additional loss of tax as, unfortunately, some companies might bring forward deductions or receipts so that they arise before the commencement date. These matters are always a challenge when considering anti-avoidance legislation, and it is difficult to strike the right balance.
