Finance Bill — Schedule 8 — Financing of companies etc: transfer pricing and loan relationships — 13 Jun 2005 at 21:45

I beg to move amendment No. 18, in page 125, line 45, leave out from beginning to end of line 23 on page 126.

Schedule 28 AA of the Income and Corporation Taxes Act 1988 provides that where an interest payment is disallowed or reduced under the transfer pricing rules, thus increasing the tax payable by one party to the transaction, a corresponding adjustment is available to the other party. That is a sensible measure, which avoids double taxation occurring where part of a transaction has been disallowed under the transfer pricing rules.

I beg to move amendment No. 26, in page 126, line 23, at end insert-

'( ) Paragraph 5D shall be amended as follows-Leave out subparagraphs (1) to (6) and replace with-

I beg to move amendment No. 20, in page 126, line 25, leave out paragraph 2.

The Committee having divided: Ayes 333, Noes 157.

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