Clause 181 - Transfers within a group by companies carrying on ring fence trade

Part of Finance Bill – in a Public Bill Committee at 4:45 pm on 19 June 2012.

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Photo of Cathy Jamieson Cathy Jamieson Shadow Minister (Treasury) 4:45, 19 June 2012

This clause is technical and considered relatively uncontroversial by the industry. It ensures consistency of tax treatment of all gains and losses within the so-called ring fence. It amends section 171A of the Taxation of Chargeable Gains Act 1992, which provides for an election to transfer a gain or loss from one company to another member of the group. It restricts the scope of section 171A. Under the current legislation, where there is a transfer of a ring-fence chargeable gain from a ring-fence company to a non-ring fence company, the ring-fence gain is not subject to a supplementary charge, because the non-ring-fence company does not fall within the scope of the supplementary charge. I am sure that that is known to everyone in detail.

I want to make a few comments so that the Minister can, if she wishes, bring up any concerns or issues relating to the measures. I understand that we want to reach a certain point in the Bill—having given the measures proper scrutiny, of course—in good time for 7.45 pm, when people may have other commitments, although the Scots among us may perhaps take a different view on that. I will therefore restrict my remarks.