Clause 35
Finance Bill
4:30 pm
Mark Hoban (Shadow Minister, Treasury; Fareham, Conservative)
Is there a workaround that HMRC could introduce? As I said in my remarks, a purely UK company would still have to work out whether it passed the gateway test even though it had no overseas parent or overseas external debt. Is there guidance? I hate asking for HMRC guidance and I argued against it last year. Is there a pragmatic solution that would say that a UK-only group need not go through the calculations set out in the gateway test?