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I beg to move, That the clause be read a Second time.
We now come to the last of our debates on the Finance Bill today. New clause 12 would require a report by the Chancellor within six months of Royal Assent, setting out further proposals to reduce the tax advantages...
I beg to move, That the clause be read a Second time.
We now come to the last of our debates on the Finance Bill today. New clause 12 would require a report by the Chancellor within six months of Royal Assent, setting out further proposals to reduce the tax advantages...
To ask the Chancellor of the Exchequer what amount of quoted eurobonds were issued by companies within the charge to UK corporation tax or income tax in circumstances where there is only one noteholder; what total interest was paid on those Eurobonds; and how much such interest was (a) allowed...
To ask the Chancellor of the Exchequer what amount of quoted eurobonds were issued by companies within the charge to UK corporation tax or income tax in circumstances where there is only one noteholder; what total interest was paid on those Eurobonds; and how much such interest was (a) allowed...
For the purposes of thin capitalisation eurobonds are treated no differently from other forms of debt finance therefore HMRC does not separately identify eurobond finance in its record. The cost of the work required to separate the data relating specifically to eurobond issues from other debt finance would be disproportionate.
HMRC has used eurobond issues as a marker for identifying thin capitalisation risk to ensure that the thin capitalisation risk posed by eurobond issues is fully addressed.
To ask Her Majesty’s Government what plans they have to review the Eurobond exemption.[HL2984]
To ask Her Majesty’s Government what plans they have to review the Eurobond exemption.[HL2984]
Recent articles in the press have suggested that £500m is being lost each year as a result of the quoted Eurobond exemption, however this figure is misleading, as it conflates a number of issues and the calculations are based on questionable methodology.
Last year, HMRC consulted on a number of rules regarding the taxation of interest, including a possible restriction of the quoted Eurobond exemption where the interest is paid between companies in the same group. It was clear from the responses that this change would not have achieved the desired result.
The Government is exploring the issue further as part of the wider package of work being undertaken by the OECD and G20 on base erosion and profit shifting, which the UK has been pushing forward.
To ask Her Majesty’s Government what were the grounds on which they agreed with Her Majesty's Revenue and Customs to allow the use of the Eurobond exemption by a range of United Kingdom companies.[HL2870]
To ask Her Majesty’s Government what were the grounds on which they agreed with Her Majesty's Revenue and Customs to allow the use of the Eurobond exemption by a range of United Kingdom companies.[HL2870]
Since 1984 there has been a statutory exemption from the requirement to withhold tax on interest paid to holders of quoted Eurobonds (broadly, listed securities denominated in non-Sterling currencies). It is one of a number of exemptions from the duty to withhold tax from interest.
The quoted Eurobond exemption does not determine whether, or how much, interest is deductible for tax purposes. Corporation tax rules prevent companies from deducting excessive amounts of interest.
Last year, HMRC consulted on a number of rules regarding the taxation of interest, including a possible restriction of the quoted Eurobond exemption where the interest is paid between companies in the same group. It was clear from the responses that this change would not have achieved the desired result.
The Government decided to look at the rules as part of the wider package of work being undertaken by the OECD and G20 on base erosion and profit shifting, which the UK has been pushing forward.
To ask Her Majesty’s Government what is the latest estimated cost per year of allowing the use of the Eurobond exemption for tax minimisation.[HL2871]
To ask Her Majesty’s Government what is the latest estimated cost per year of allowing the use of the Eurobond exemption for tax minimisation.[HL2871]
Recent articles in the press have suggested that £500 million is being lost each year as a result of the Quoted Eurobond Exemption, however this figure is misleading, as it conflates a number of issues and the calculations are based on questionable methodology.
In March 2012 HMRC published a consultation document on possible changes to income tax rules on interest. This document included an estimate of the Exchequer impact of the possible withdrawal of the
quoted Eurobond exemption for intra-group Eurobonds. The estimate was £200 million a year from 2013/14 to 2015/16 and was provisional.
The number of Eurobonds issued intra-group is not known and one of the purposes of the consultation was to identify the likely real impact. It became apparent that the changes suggested in the consultation would not have yielded that amount and would have had adverse effects on companies that are entitled to pay gross under double taxation treaties.
The Government is exploring the issue further in the context of a wider consideration of cross-border payments.
To my memory, I have never been lobbied on this particular issue. I looked at it this morning. The Treasury has listened very carefully to the arguments and has made the decisions for the reasons that the hon. Lady knows.
To my memory, I have never been lobbied on this particular issue. I looked at it this morning. The Treasury has listened very carefully to the arguments and has made the decisions for the reasons that the hon. Lady knows.
Q5
.
Seema Malhotra (Feltham and Heston) (Lab/Co-op):
Yesterday, The Independent reported the Government’s failure to close the quoted Eurobond tax loophole, which could be losing the Exchequer £500 million a year. Has the Prime Minister ever been lobbied on the loophole? Will he now pledge to close it immediately?
Q5
.
Seema Malhotra (Feltham and Heston) (Lab/Co-op):
Yesterday, The Independent reported the Government’s failure to close the quoted Eurobond tax loophole, which could be losing the Exchequer £500 million a year. Has the Prime Minister ever been lobbied on the loophole? Will he now pledge to close it immediately?
Q5
.
Seema Malhotra (Feltham and Heston) (Lab/Co-op):
Yesterday, The Independent reported the Government’s failure to close the quoted Eurobond tax loophole, which could be losing the Exchequer £500 million a year. Has the Prime Minister ever been lobbied on the loophole? Will he now pledge to close it immediately?
To my memory, I have never been lobbied on this particular issue. I looked at it this morning. The Treasury has listened very carefully to the arguments and has made the decisions for the reasons that the hon. Lady knows.
My Lords, I am delighted to have the opportunity to introduce the debate on this report. Sadly, I am rather less delighted by the circumstances that required the report to be written and that make today’s debate so urgent and topical. The report was a joint effort based on work...
My Lords, I am delighted to have the opportunity to introduce the debate on this report. Sadly, I am rather less delighted by the circumstances that required the report to be written and that make today’s debate so urgent and topical. The report was a joint effort based on work...
My Lords, the noble Lord, Lord Harrison, and his committee have produced an excellent report on the most critical issue facing the European economy since the start of the EU. They are to be congratulated on it.
Given all that has happened—and indeed has not happened—in the eurozone since the report...
My Lords, the noble Lord, Lord Harrison, and his committee have produced an excellent report on the most critical issue facing the European economy since the start of the EU. They are to be congratulated on it.
Given all that has happened—and indeed has not happened—in the eurozone since the report...
My Lords, one of the small pleasures of working in Brussels for eight years as general secretary of the European Trade Union Confederation was to be examined periodically by the House of Lords European Union Committee and to talk with others in the waiting room about just how serious and...
My Lords, one of the small pleasures of working in Brussels for eight years as general secretary of the European Trade Union Confederation was to be examined periodically by the House of Lords European Union Committee and to talk with others in the waiting room about just how serious and...
My Lords, it has been a privilege to serve on the Select Committee and to participate in at least some of its deliberations on this subject. I thank the noble Lords, Lord Harrison and Lord Roper, for presiding over those deliberations at a time of great sensitivity and urgency to...
My Lords, it has been a privilege to serve on the Select Committee and to participate in at least some of its deliberations on this subject. I thank the noble Lords, Lord Harrison and Lord Roper, for presiding over those deliberations at a time of great sensitivity and urgency to...
My Lords, might the noble Lord also remark that well over 75% of Greeks who have been polled want Greece to stay in the eurozone?
My Lords, might the noble Lord also remark that well over 75% of Greeks who have been polled want Greece to stay in the eurozone?
I believe it is nearer 80%, which is an indication that the traditional parties might be worthy of greater support than Syriza, but it is not for us to comment on the internal politics that are leading up to the June elections in Greece.
I believe that it is not sensible...
I believe it is nearer 80%, which is an indication that the traditional parties might be worthy of greater support than Syriza, but it is not for us to comment on the internal politics that are leading up to the June elections in Greece.
I believe that it is not sensible...
My Lords, both the noble Lord, Lord Monks, and my noble friend Lord Maclennan have warned us against advising or criticising other countries in these matters. It always seems to me that one advantage of the privacy of your Lordships’ Chamber is that we can freely give advice to the...
My Lords, both the noble Lord, Lord Monks, and my noble friend Lord Maclennan have warned us against advising or criticising other countries in these matters. It always seems to me that one advantage of the privacy of your Lordships’ Chamber is that we can freely give advice to the...
I agree with the noble Lord’s analysis entirely up to now. However, does he agree with me that if the drachma collapsed, as it certainly would, everybody would want to borrow in it and have their liabilities in drachmas and their assets in euros, and that that would be part...
I agree with the noble Lord’s analysis entirely up to now. However, does he agree with me that if the drachma collapsed, as it certainly would, everybody would want to borrow in it and have their liabilities in drachmas and their assets in euros, and that that would be part...
My goodness, the noble Lord is certainly a speculator.
If Germany is prepared to pay not the cost of bailing out Greece but the cost of redeeming the Greek euro debt which already exists, we have to think of something better than going into a Mickey Mouse currency such as the...
My goodness, the noble Lord is certainly a speculator.
If Germany is prepared to pay not the cost of bailing out Greece but the cost of redeeming the Greek euro debt which already exists, we have to think of something better than going into a Mickey Mouse currency such as the...
The noble Lord has painted a fascinating scenario, but how does he get out from under the problem he referred to whereby, in a sense, the demagogues fail to acknowledge that the real fall in living standards would be a lot greater in the drachma devaluation scenario than in the...
The noble Lord has painted a fascinating scenario, but how does he get out from under the problem he referred to whereby, in a sense, the demagogues fail to acknowledge that the real fall in living standards would be a lot greater in the drachma devaluation scenario than in the...
When Sub-Committee A looked at the bailout, we saw again and again that the figures produced as necessary to prevent a catastrophe became ever greater by magnitudes. There is the old cliché about “A billion here and a billion there—you are talking serious money”; we almost reached the stage where...
When Sub-Committee A looked at the bailout, we saw again and again that the figures produced as necessary to prevent a catastrophe became ever greater by magnitudes. There is the old cliché about “A billion here and a billion there—you are talking serious money”; we almost reached the stage where...
I am rather uncertain as to how, if the Greeks basically default but stay with the euro, they would raise new debt in euros.
I am rather uncertain as to how, if the Greeks basically default but stay with the euro, they would raise new debt in euros.
I do not think that they could do so as such, except that, as I say, you might have a euro project in which people would invest. It would perhaps be somewhat similar to the private finance initiatives that have been used by the British Government—not entirely with success, maybe,...
I do not think that they could do so as such, except that, as I say, you might have a euro project in which people would invest. It would perhaps be somewhat similar to the private finance initiatives that have been used by the British Government—not entirely with success, maybe,...