Clause 42
Finance Bill
9:15 am
Mark Hoban (Shadow Minister, Treasury; Fareham, Conservative)
I wish to raise an issue about the clause. The changes in the clause enable transactions between rated parties so that, where there is a waiver of a property or trade debt, these releases will not be taxable in the debtor company nor will there be a tax relief in the creditor company. So, within the group these changes are tax-neutral.
However, there are other inter-company balances that arise other than through trade or property debts. It has been suggested that it might be helpful to enable long-standing inter-company balances to be written off and relief to be given, so that there is no taxable transaction taking place in the debtor company nor is the tax relief given in the creditor company. I just wonder whether the Government have thought about extending the relief to companies in those circumstances.