Schedule 21
Finance Bill
9:15 am
Mark Hoban (Shadow Minister, Treasury; Fareham, Conservative)
I have just one question about schedule 21. Paragraph 2 states that
“the arrangements cause the company or any other company to gain a tax advantage (other than a negligible tax advantage).”
Schedule 21 introduces anti-avoidance provisions, but why is there not a more traditional motive test? Paragraph 2 offers a very broad definition, but when anti-avoidance is involved, one normally expects the more traditional wording where the main purpose involves tax avoidance. Paragraph 2 might cover a much broader range of transactions than would normally be covered by a targeted anti-avoidance measure.