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Written question asked by Peter Dowd (Labour) on Wednesday, 12 December 2018, in the House of Commons. It was due for an answer on Monday, 17 December 2018 (named day). It was answered by Mel Stride (Conservative) on Monday, 17 December 2018 on behalf of the Treasury.

Advance Pricing Agreements

Question

To ask the Chancellor of the Exchequer, how much revenue has accrued to the public purse from anti-avoidance measures to tackle groups of companies using intra-group loans or derivatives to reduce the group’s tax bill.

Answer

There have been a large number of measures over the years which operate to counter Corporation Tax avoidance using intra-group loans and derivatives. The key measures are the ‘unallowable purpose’ rules (sections 441 and 690 of Corporation Tax Act 2009), the transfer pricing rules (Part 4 of Taxation (International and Other Provisions) Act 2010 (“TIOPA 2010”)), the group mismatch scheme rules (Part 21B of Corporation Tax Act 2010 (“CTA 2010”)), the tax mismatch scheme rules (Part 21BA of CTA 2010), the hybrid and other mismatches rules (Part 6A of TIOPA 2010), the controlled foreign companies rules (Part 9A of TIOPA 2010) and the corporate interest restriction rules (Part 10 of TIOPA 2010). Taken together these measures have been successful in protecting revenues, but it is not possible to say how much would otherwise have been lost.

Secondary information

Type
Written question
Reference
201707
Session
2017-19
Subjects
Taxation Advance pricing agreements
Link
View this Written question on www.parliament.uk