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1126814

	registered interest
	date	15/05/2019
	answering body	Treasury
	answering dept id	14
	answering dept short name	Treasury
	answering dept sort name	Treasury
	hansard heading	Multinational Companies: Taxation
	house id	1
	legislature	25259 pref label House of Commons
	question text	To ask the Chancellor of the Exchequer, pursuant to Answer of 29 April 2019 to Question 247155 on Multinational Companies: Taxation; for what reason Jersey, Guernsey and the Isle of Man were not included in the list of countries with a full tax treaty with the UK; and whether these jurisdictions will be covered by the offshore receipts in respect of intangible property rule.
	tabling member constituency	Oxford East
	tabling member printed	Anneliese Dodds
	uin	254875
	answer	answer is ministerial correction date of answer 20/05/2019 answer text <p>The scope of the legislation “Offshore Receipts in respect of Intangible Property” is limited to territories with which the UK does not have a full tax treaty. A “full treaty territory” is defined in the legislation as a treaty containing a non-discrimination provision. A non-discrimination provision is defined by reference to nationals of a state. Jersey, Guernsey and the Isle of Man are not “states”, they are territories for which the UK is responsible and so cannot meet that condition.</p><p> </p><p>It follows that the Crown Dependencies are within scope of the legislation. The government has committed to respecting its international obligations in respect of this measure. As such the provisions of the relevant treaties will apply to any arrangements involving the Crown Dependencies that are subject to the legislation, and the UK will provide for treaty relief where applicable.</p> answering member constituency Central Devon answering member printed Mel Stride question first answered 20/05/2019 14:38:35 answering member 3935 label Biography information for Mel Stride
	tabling member	4657 label Biography information for Anneliese Dodds

1124686

	registered interest
	date	03/05/2019
	answering body	Treasury
	answering dept id	14
	answering dept short name	Treasury
	answering dept sort name	Treasury
	hansard heading	Multinational Companies: Taxation
	house id	1
	legislature	25259 pref label House of Commons
	question text	To ask the Chancellor of the Exchequer, whether his Department has made an assessment of the effect of the European Commission decision that the UK must recover illegal State aid from the multinational companies that benefited from the group financing exemption of the UK's Controlled Foreign Company (CFC) rules.
	tabling member constituency	Oxford East
	tabling member printed	Anneliese Dodds
	uin	250796
	answer	answer is ministerial correction date of answer 09/05/2019 answer text <p>As the European Commission’s State aid decision makes clear, the existence and quantification of state aid in relation to the group financing exemption of the UK’s Controlled Foreign Company (CFC) rules can only be ascertained by a detailed examination of the facts and circumstances of each case. The decision also makes it clear that no legislative changes are required going forwards.</p> answering member constituency Central Devon answering member printed Mel Stride question first answered 09/05/2019 13:30:01 answering member 3935 label Biography information for Mel Stride
	tabling member	4657 label Biography information for Anneliese Dodds

1122697

	registered interest
	date	24/04/2019
	answering body	Treasury
	answering dept id	14
	answering dept short name	Treasury
	answering dept sort name	Treasury
	hansard heading	Multinational Companies: Taxation
	house id	1
	legislature	25259 pref label House of Commons
	question text	To ask the Chancellor of the Exchequer, pursuant to the Answer of 23 April 2019 to Question 242951 on Multinational Companies: Taxation, if he will publish each country that the HM Treasury considers to be a low-tax jurisdiction with which the UK does not have a full tax treaty for which offshore receipts in relation to the intangible property measure in the Finance Act 2019 will be applicable.
	tabling member constituency	Oxford East
	tabling member printed	Anneliese Dodds
	uin	247155
	answer	answer is ministerial correction date of answer 29/04/2019 answer text <p>The <em>Offshore receipts in respect of intangible property</em> measure applies to entities that are not resident either in the UK, or in a jurisdiction with which the UK has a full tax treaty, meaning a tax treaty containing an appropriate non-discrimination article.</p><p> </p><p>The measure only applies where the tax paid in the local territory on the relevant intangible property income is less than 50% of the charge that would otherwise arise under the measure. This tax rate test applies on an entity-by-entity basis, rather than at the level of the jurisdiction.</p><p> </p><p>The measure may also apply to entities that are resident in territories where those entities are liable to tax on a territorial basis, subject to the UK’s treaty obligations and the tax rate test.</p><p> </p><p>A list of jurisdictions with which the UK has a full tax treaty can be found here: <a href="https://www.gov.uk/hmrc-internal-manuals/international-manual/intm412090" target="_blank">https://www.gov.uk/hmrc-internal-manuals/international-manual/intm412090</a>.</p> answering member constituency Central Devon answering member printed Mel Stride question first answered 29/04/2019 15:02:04 answering member 3935 label Biography information for Mel Stride
	tabling member	4657 label Biography information for Anneliese Dodds

1110756

	registered interest
	date	09/04/2019
	answering body	Treasury
	answering dept id	14
	answering dept short name	Treasury
	answering dept sort name	Treasury
	hansard heading	Multinational Companies: Taxation
	house id	1
	legislature	25259 pref label House of Commons
	question text	To ask the Chancellor of the Exchequer, which jurisdictions will be within the scope of the offshore receipts in relation to the intangible property measure in the Finance Act 2019.
	tabling member constituency	Oxford East
	tabling member printed	Anneliese Dodds
	uin	242951
	answer	answer is ministerial correction date of answer 23/04/2019 answer text <p>The <em>Offshore receipts in respect of intangible property</em> measure targets multinational groups that realise intangible property income from UK sales in low or no-tax jurisdictions.</p><p> </p><p>The government has been clear that this measure will be applied in compliance with the UK’s international obligations. This means that the measure will only apply to low-tax jurisdictions with which the UK does not have a full tax treaty.</p> answering member constituency Central Devon answering member printed Mel Stride question first answered 23/04/2019 15:51:38 answering member 3935 label Biography information for Mel Stride
	tabling member	4657 label Biography information for Anneliese Dodds

1109704

	registered interest
	date	04/04/2019
	answering body	Treasury
	answering dept id	14
	answering dept short name	Treasury
	answering dept sort name	Treasury
	hansard heading	Multinational Companies: Taxation
	house id	1
	legislature	25259 pref label House of Commons
	question text	To ask the Chancellor of the Exchequer, what discussions he has had with his international counterparts on the implementation of measures relating to offshore receipts in respect of intangible property.
	tabling member constituency	Oxford East
	tabling member printed	Anneliese Dodds
	uin	241089
	answer	answer is ministerial correction date of answer 09/04/2019 answer text <p>The Chancellor has regular discussions with his international counterparts on matters relating to international tax policy.</p> answering member constituency Central Devon answering member printed Mel Stride question first answered 09/04/2019 16:09:12 answering member 3935 label Biography information for Mel Stride
	tabling member	4657 label Biography information for Anneliese Dodds

1078512

	registered interest
	date	27/02/2019
	answering body	Treasury
	answering dept id	14
	answering dept short name	Treasury
	answering dept sort name	Treasury
	hansard heading	Multinational Companies: Taxation
	house id	1
	legislature	25259 pref label House of Commons
	question text	To ask the Chancellor of the Exchequer, how many companies with (a) assets over £2 billion or (b) a turnover of over £200 million have published their tax strategy.
	tabling member constituency	Bootle
	tabling member printed	Peter Dowd
	uin	226686
	answer	answer is ministerial correction date of answer 04/03/2019 answer text <p>HMRC does not keep a central record that shows which companies with assets over £2 billion or a turnover of over £200 million have published their tax strategies.</p><p> </p> answering member constituency Central Devon answering member printed Mel Stride question first answered 04/03/2019 17:18:57 answering member 3935 label Biography information for Mel Stride
	tabling member	4397 label Biography information for Peter Dowd

1035229

	registered interest
	date	04/01/2019
	answering body	Treasury
	answering dept id	14
	answering dept short name	Treasury
	answering dept sort name	Treasury
	hansard heading	Multinational Companies: Taxation
	house id	1
	legislature	25259 pref label House of Commons
	question text	To ask the Chancellor of the Exchequer, if he will make an assessment of the potential merits of increasing taxes on global corporations and using any additional revenue raised to the public purse to reduce taxes for families.
	tabling member constituency	South Holland and The Deepings
	tabling member printed	Sir John Hayes
	uin	205185
	answer	answer is ministerial correction date of answer 14/01/2019 answer text <p>Since 2010, this government has taken unprecedented action to ensure that large multinationals pay their fair share of tax in the UK. For example, at Budget 2018, the Chancellor announced the introduction of a new Digital Services Tax (DST) from April 2020. This will raise around £1.5bn across four years.</p><p> </p><p>At the same time, the government remains committed to keeping taxes low for working people. A typical basic rate taxpayer will pay £1,200 less in tax in 2019-20 than in 2010, and we’ve announced plans to freeze fuel duty for the ninth year in a row.</p><p> </p><p>The government will continue to keep all tax policy under review.</p> answering member constituency Central Devon answering member printed Mel Stride question first answered 14/01/2019 14:47:51 answering member 3935 label Biography information for Mel Stride
	tabling member	350 label Biography information for Sir John Hayes

1024271

	registered interest
	date	12/12/2018
	answering body	Treasury
	answering dept id	14
	answering dept short name	Treasury
	answering dept sort name	Treasury
	hansard heading	Multinational Companies: Taxation
	house id	2
	legislature	25277 pref label House of Lords
	question text	To ask Her Majesty's Government what steps they are taking to collect more tax revenue from large multinational companies.
	tabling member printed	Lord Taylor of Warwick
	uin	HL12265
	answer	answer is ministerial correction date of answer 20/12/2018 answer text <p>The Government has taken significant steps, domestically and internationally, to ensure that multinationals pay the right amount of tax in the UK.</p><p> </p><p>The UK has led on initiating the OECD Base Erosion and Profit Shifting project and in delivering its recommendations into domestic legislation, for example the corporate interest restriction.</p><p> </p><p>In April 2015, the Government introduced the Diverted Profits Tax which seeks to counter contrived arrangements used to divert profits away from the UK.</p><p> </p><p>At Budget 2018, the Chancellor announced the introduction of the Digital Services Tax, intended to ensure that digital businesses pay UK tax which reflects the value they derive from UK users.</p> answering member printed Lord Bates question first answered 20/12/2018 14:39:12 answering member 1091 label Biography information for Lord Bates
	tabling member	1796 label Biography information for Lord Taylor of Warwick

993599

	registered interest
	date	23/10/2018
	answering body	Treasury
	answering dept id	14
	answering dept short name	Treasury
	answering dept sort name	Treasury
	hansard heading	Multinational Companies: Taxation
	house id	1
	legislature	25259 pref label House of Commons
	question text	To ask the Chancellor of the Exchequer, how much revenue was lost to the public purse as a result of the exemption for regulatory capital in section 259N(3)(b) Chapter 8 Part 6A Taxation (International and Other Provisions) Act 2010 in each year since the introduction of that exemption.
	tabling member constituency	Oxford East
	tabling member printed	Anneliese Dodds
	uin	182824
	answer	answer is ministerial correction date of answer 26/10/2018 answer text <p>As a matter of corporation tax policy, with the aim of improving financial stability, the UK allows certain deductions for the costs of regulatory capital. The exemption referred to helps to ensure that the Hybrid and Other Mismatch Rules act in a way consistent with this policy. As such, there is no question of any tax revenue being “lost” as a result of the exemption.</p><p>It is not possible to provide details of the tax effect arising from the exemption for regulatory capital in section 259N(3)(b), Chapter 8, Part 6A of the Taxation (International and other Provisions) Act 2010.</p><p>The Hybrid and other mismatches regime came into force on 1 January 2017. The majority of corporation tax returns which will reflect the impact of these rules have not yet been received.</p> answering member constituency Central Devon answering member printed Mel Stride question first answered 26/10/2018 13:46:56 answering member 3935 label Biography information for Mel Stride
	tabling member	4657 label Biography information for Anneliese Dodds

987760

	registered interest
	date	15/10/2018
	answering body	Treasury
	answering dept id	14
	answering dept short name	Treasury
	answering dept sort name	Treasury
	hansard heading	Multinational Companies: Taxation
	house id	1
	legislature	25259 pref label House of Commons
	question text	To ask the Chancellor of the Exchequer, what estimate he has made of the number of additional companies that will be within scope of Chapter 8 of Part 6A of the Taxation (International and Other Provisions) Act 2010 in the event that new subsection 259HA(5)(b) is added as set out in clause 38 of the draft Finance Bill.
	tabling member constituency	Oxford East
	tabling member printed	Anneliese Dodds
	uin	179307
	answer	answer is ministerial correction date of answer 18/10/2018 answer text <p>This measure ensures that the UK hybrid and other mismatch rules are fully compliant with the Anti-Tax Avoidance Directive, ATAD. No estimate has been made in relation to the number of additional companies that may be within scope of the hybrid mismatch rules as a result of this proposed amendment. Clause 38 introduces a minor change to the rules in relation to permanent establishments. The expected yield from this change is negligible. HMRC are not aware of current schemes or arrangements which would fall within the scope of the hybrid mismatch rules as a result of this proposed change to Chapter 8 of Part 6A TIOPA 2010. In addition, the existing hybrid mismatch rules already deal with the majority of mismatches involving permanent establishments.</p> answering member constituency Central Devon answering member printed Mel Stride question first answered 18/10/2018 12:55:45 answering member 3935 label Biography information for Mel Stride
	tabling member	4657 label Biography information for Anneliese Dodds