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1129661

registered interest
date	04/06/2019
answering body	Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	Treasury
hansard heading	Advance Pricing Agreements
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, how many applications for Advance Thin Capitalisation Agreements were made in 2017-2018.
tabling member constituency	Oxford East
tabling member printed	Anneliese Dodds
uin	260108
answer	answer is ministerial correction date of answer 10/06/2019 answer text <p>HMRC publishes data regarding Advanced Thin Capitalisation Agreements (ATCAs) on an annual basis. The latest publication which covers data up to 2017-18 is available at the following link:</p><p> </p><p><a href="https://www.gov.uk/government/publications/transfer-pricing-and-diverted-profits-tax-statistics-to-2017-to-2018" target="_blank">https://www.gov.uk/government/publications/transfer-pricing-and-diverted-profits-tax-statistics-to-2017-to-2018</a>.</p><p> </p><p>Information for 2018-19 will be published later this year. This will include the number of Advanced Thin Capitalisation Agreements HMRC has entered into during the year. HMRC does not currently centrally record and monitor the number of applications made in the year.</p> answering member constituency Hereford and South Herefordshire answering member printed Jesse Norman grouped question UIN 260107 question first answered 10/06/2019 14:38:08 answering member 3991 label Biography information for Jesse Norman
tabling member	4657 label Biography information for Anneliese Dodds

1128288

registered interest
date	22/05/2019
answering body	Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	Treasury
hansard heading	Employment Agencies: Tax Avoidance
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, how many of the schemes that have been disclosed under the Disclosure of Tax Avoidance Scheme involve the activities of recruitment agencies.
tabling member constituency	Oxford East
tabling member printed	Anneliese Dodds
uin	257549
answer	answer is ministerial correction date of answer 05/06/2019 answer text <p>The Disclosure of Tax Avoidance Scheme (DOTAS) regime does not expressly require disclosers to tell HMRC whether a scheme involves a recruitment agency. HMRC reviews all disclosures under DOTAS and challenges schemes as appropriate as part of its risk based compliance strategy.</p> answering member constituency Hereford and South Herefordshire answering member printed Jesse Norman question first answered 05/06/2019 15:55:29 answering member 3991 label Biography information for Jesse Norman
tabling member	4657 label Biography information for Anneliese Dodds

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

1126865

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	Public Sector: Tax Avoidance
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, which public sector organisations HMRC have identified as engaging in paying workers through disguised renumeration schemes.
tabling member constituency	Oxford East
tabling member printed	Anneliese Dodds
uin	254876
answer	answer is ministerial correction date of answer 20/05/2019 answer text HMRC is unable to provide information on specific taxpayers due to its legal obligation to uphold taxpayer confidentiality. HMRC is committed to tackling tax avoidance at all levels across all organisations, including public bodies. It works closely with public bodies to support them with their tax affairs and ensure they pay the right amount.<p> </p><p>It is possible for individuals to use disguised remuneration tax avoidance schemes without the participation or knowledge of the entity that engages them. Individuals, working for public bodies, identified in the course of HMRC’s compliance work as using a tax avoidance scheme would be investigated in the same way as any other scheme user.</p> answering member constituency Central Devon answering member printed Mel Stride question first answered 20/05/2019 14:43:04 answering member 3935 label Biography information for Mel Stride
tabling member	4657 label Biography information for Anneliese Dodds

1125877

registered interest
date	10/05/2019
answering body	Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	Treasury
hansard heading	Taxation
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, what the incidence of the taxation of carried interest has been annually since 2005.
tabling member constituency	Oxford East
tabling member printed	Anneliese Dodds
uin	252881
answer	answer is ministerial correction date of answer 15/05/2019 answer text <p>I refer the Honourable Member to the answer that I gave on 23 April 2019 to PQ UIN 243571. In addition, since 6 April 2016 Income Tax has been levied on carried interest that relates to certain short term investments.</p> answering member constituency Central Devon answering member printed Mel Stride question first answered 15/05/2019 15:43:28 answering member 3935 label Biography information for Mel Stride
tabling member	4657 label Biography information for Anneliese Dodds

1125878

registered interest
date	10/05/2019
answering body	Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	Treasury
hansard heading	Public Sector: Tax Avoidance
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, how many public sector organisations paid workers through disguised remuneration loans.
tabling member constituency	Oxford East
tabling member printed	Anneliese Dodds
uin	252882
answer	answer is ministerial correction date of answer 15/05/2019 answer text <p>Disguised remuneration (DR) loan schemes are contrived arrangements that pay loans in place of ordinary remuneration with the sole purpose of avoiding income tax and National Insurance contributions. The loans are provided on terms that mean they are not repaid in practice, so they are no different to normal income and are, and always have been, taxable.</p><p> </p><p>Individuals, working for public bodies, identified in the course of HMRC’s compliance work as using a tax avoidance scheme would be investigated in the same way as any other scheme user.</p><p> </p><p>The Government estimates that around 50,000 individuals could be affected by the charge on DR loans. The charge applies to all users of DR tax avoidance schemes, it does not single out a specific group or industry. It is possible for individuals to use DR tax avoidance schemes without the participation or knowledge of the entity that engages them.</p><p> </p> answering member constituency Central Devon answering member printed Mel Stride question first answered 15/05/2019 15:41:27 answering member 3935 label Biography information for Mel Stride
tabling member	4657 label Biography information for Anneliese Dodds

1125369

registered interest
date	08/05/2019
answering body	Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	Treasury
hansard heading	Employment Agencies: Tax Avoidance
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, what assessment his Department has made of the level of involvement of recruitment agencies in disguised remuneration loans.
tabling member constituency	Oxford East
tabling member printed	Anneliese Dodds
uin	252056
answer	answer is ministerial correction date of answer 13/05/2019 answer text <p>DR schemes are contrived arrangements that pay loans in place of ordinary remuneration, usually through an offshore trust, with the sole purpose of avoiding income tax and National Insurance contributions. The loans are provided on terms that mean they are not repaid in practice, so they are no different to normal income and are, and always have been, taxable.</p><p> </p><p>HM Revenue and Customs (HMRC) will always seek payment of the loan charge from employers in the first instance. It is only where HMRC cannot reasonably collect from the employer, for example where the employer is no longer in existence or is based offshore, that the individual will be liable to pay the tax due. Around 75% of overall yield from the measure is expected to come from employers.</p><p> </p><p>Only an employer, or umbrella company established for the purpose, can originate a DR scheme. Recruitment agencies match individuals with engagers who require their labour. In most cases recruitment agencies do not employ the individual in question. Where a recruitment agency used a DR scheme to reward their employees they will be liable to pay the loan charge in the first instance.</p> answering member constituency Central Devon answering member printed Mel Stride grouped question UIN 252057 question first answered 13/05/2019 15:46:10 answering member 3935 label Biography information for Mel Stride
tabling member	4657 label Biography information for Anneliese Dodds

1125370

registered interest
date	08/05/2019
answering body	Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	Treasury
hansard heading	Employment Agencies: Tax Avoidance
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, how many recruitment agencies have been implicated in loan charge cases.
tabling member constituency	Oxford East
tabling member printed	Anneliese Dodds
uin	252057
answer	answer is ministerial correction date of answer 13/05/2019 answer text <p>DR schemes are contrived arrangements that pay loans in place of ordinary remuneration, usually through an offshore trust, with the sole purpose of avoiding income tax and National Insurance contributions. The loans are provided on terms that mean they are not repaid in practice, so they are no different to normal income and are, and always have been, taxable.</p><p> </p><p>HM Revenue and Customs (HMRC) will always seek payment of the loan charge from employers in the first instance. It is only where HMRC cannot reasonably collect from the employer, for example where the employer is no longer in existence or is based offshore, that the individual will be liable to pay the tax due. Around 75% of overall yield from the measure is expected to come from employers.</p><p> </p><p>Only an employer, or umbrella company established for the purpose, can originate a DR scheme. Recruitment agencies match individuals with engagers who require their labour. In most cases recruitment agencies do not employ the individual in question. Where a recruitment agency used a DR scheme to reward their employees they will be liable to pay the loan charge in the first instance.</p> answering member constituency Central Devon answering member printed Mel Stride grouped question UIN 252056 question first answered 13/05/2019 15:46:10 answering member 3935 label Biography information for Mel Stride
tabling member	4657 label Biography information for Anneliese Dodds

1125372

registered interest
date	08/05/2019
answering body	Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	Treasury
hansard heading	Public Sector: Tax Avoidance
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, whether his Department is undertaking a review of internal (a) advice and (b) procedures on public sector organisations engaging in tax avoidance schemes.
tabling member constituency	Oxford East
tabling member printed	Anneliese Dodds
uin	252058
answer	answer is ministerial correction date of answer 13/05/2019 answer text HMRC is committed to tackling tax avoidance and evasion at all levels to ensure that everyone, no matter who they are, pays the right amount of tax at the right time. It keeps its policies under constant review, including those affecting public sector bodies. HMRC works closely with public bodies to support them with their tax affairs and ensure they pay the right amount. answering member constituency Central Devon answering member printed Mel Stride question first answered 13/05/2019 15:50:04 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