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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

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

861195

registered interest
date	13/03/2018
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 Mr Chancellor of the Exchequer, what estimate he has made of the potential monies that would accrue to the public purse of the introduction of revenue-based taxes on multinational companies.
tabling member constituency	Birkenhead
tabling member printed	Frank Field
uin	132344
answer	answer is ministerial correction date of answer 16/03/2018 answer text <p>The UK applies value-added tax to businesses’ supplies of goods and services to UK consumers. Corporation tax is imposed on a business’s profits relating to value generated through UK activities. The government continues to support the principle that a multinational group’s profits should be taxed in the countries in which it generates value. It does not, for example, believe that the profits of a business that undertakes all of its activities in the UK should be taxed in overseas markets in which the business's goods and services might be sold.</p><p>The Government has set out its receptiveness to exploring interim measures with like-minded countries, like a tax on revenues, to tax certain digital businesses which generate value from UK users. That would be designed to compensate for unrecognised user-created value pending wider reform of the international corporate tax system. The yield from such a tax would depend on its scope, rate and detailed design.</p><p> </p> answering member constituency Central Devon answering member printed Mel Stride question first answered 16/03/2018 13:52:21 answering member 3935 label Biography information for Mel Stride
tabling member	478 label Biography information for Lord Field of Birkenhead

786322

registered interest
date	07/11/2017
answering body	HM Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	CaTreasury
hansard heading	Multinational Companies: Taxation
house id	1
legislature	25259 pref label House of Commons
question text	To ask Mr Chancellor of the Exchequer, when the Government plans to bring into force Schedule 19 of the Finance Act 2016.
tabling member constituency	Birkenhead
tabling member printed	Frank Field
uin	112181
answer	answer is ministerial correction date of answer 13/11/2017 answer text <p>Schedule 19 of the Finance Act 2016 gained Royal Assent on the 15th September 2016.</p><p> </p><p>Qualifying businesses are required to publish their tax strategy in financial years commencing after this date.</p> answering member constituency Central Devon answering member printed Mel Stride question first answered 13/11/2017 15:55:24 answering member 3935 label Biography information for Mel Stride
tabling member	478 label Biography information for Lord Field of Birkenhead