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I do not have a huge amount to say on the clause. I hesitate to tread in the complex area of the tax treatment of leasing and companies, because it is not a particularly straightforward area. Clause 29 makes changes to schedule 10 to the Finance Act 2006. There has, I think, been some consultation with the industry about some of the unintended consequences of schedule 10 to that Act.
Schedule 10 was introduced to create an income tax charge on the sale of a company carrying on the qualifying business of leasing plant and machinery. The Budget note sets out that:
Schedule 10 to the Finance Act 2006 prevents a loss of tax when a lessor company changes hands. It achieves this by calculating a charge and relief designed to recoup the tax timing advantage gained from a claim to capital allowances. The legislation ensures that the charge affects the selling group and the relief benefits the buying group.
Deloitte and Touche has said that part of the problem with schedule 10 is that for leasing companies
I apologise, Mr. Hood. I am so keen to get on and talk about this that I rather overstepped the mark. I apologise, I should have left that remark to the debate on schedule 10.
The clause introduces schedule 10 to the Bill. It makes changes to the anti-avoidance rules for the sale of leasehold legislation contained in schedule 10 to Finance Act 2006, ensuring that it operates fairly and does not impede commercially driven transactions. I therefore move that it stands part of the Bill.