The Economy

Tulip Siddiq Excerpts
Wednesday 22nd May 2024

(3 weeks, 3 days ago)

Commons Chamber
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Tulip Siddiq Portrait Tulip Siddiq (Hampstead and Kilburn) (Lab)
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I thank the Minister for advance sight of his statement.

Of course it is welcome that the rate of inflation is finally slowing after three years of the Government missing every single target, but the tone-deaf victory lap we are seeing from the Government today will feel like a slap in the face to the British people who, after 14 long years of Conservative chaos, are still significantly worse off. While Conservative Ministers are popping champagne corks over the rate of food price rises, the cost of the typical family shop has gone up by nearly £1,000 since 2019—so those families will not be celebrating—and while the Chancellor and the Prime Minister gaslight ordinary British families by suggesting that the cost of living crisis is over, the costs for a two-earner household are more than £150 a week higher than they were before the last election.

The Minister claims that the economy has turned a corner, but in reality the Conservatives’ record on growth has been nothing short of pitiful. If the UK economy had grown at the average rate of the OECD in the last 14 years, it would now be £140 billion larger—that is not just about lines on a graph; it would have meant an additional £50 billion in tax revenues to invest in our public services, and more money in working people’s pockets.

I noted with interest that the Minister quoted selectively from the IMF’s report. In that report, which he cited so triumphantly, the IMF confirmed that under the Conservatives the UK was suffering from the lowest growth in the G7, and just this week the IMF said that the longer-term growth prospects of the UK “remain subdued”. This is the Conservative party’s legacy: a poorer Britain, working people worse off, and the public realm in disarray. I think the Minister may also be slightly confused about his Government’s record on tax. On the Conservatives’ watch, the tax burden is the highest in 70 years, and under the Prime Minister’s tax plans households will, on average, be £870 worse off by 2028. Those are the statistics that the Minister missed out.

In contrast to the Conservatives, who have consistently failed to explain how they will pay for their £46 billion unfunded commitment to abolish national insurance, we in the Labour party have ensured that all our plans are fully costed. Let me also make it clear that a Labour Government would not be celebrating the inflation target finally being met for the first time in years. We would not be doing a tone-deaf victory lap for overseeing a decade and a half of stagnant growth. Instead, we have pledged to deliver economic stability with tough spending rules so that we can grow our economy and keep taxes, inflation and mortgages as low as possible.

The choice at the next election is clear: five more years of chaos with the Conservatives or stability with a changed Labour party. That is why the Government are running scared. Time after time, they have chosen to bottle it rather than go to the country, but I hope that, today of all days, the Prime Minister will do the right thing. It is time for this exhausted and failing Government to step aside in the national interest, call an election, and let the responsible party take charge.

Bim Afolami Portrait Bim Afolami
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Let me start by welcoming the shadow Minister’s remarks, and by saying that no one on the Government Benches—certainly not me—feels that times are not still tough for many millions of people. We are acutely aware of that, which is why we have worked so hard over the last few years to make the difficult decisions that are required for us to guide the country through the difficulties wrought by covid, the biggest pandemic in 100 years, and by the energy shock from the war in Ukraine. No one on this side of the House minimises the difficulties that people have gone through and that many are still going through.

Let me pick up a couple of points of fact. The hon. Lady quoted the IMF, and she mentioned selective quotations. I am afraid that she wins the prize on that one: the IMF was very clear about the fact that over the next five or six years, the UK will be the fastest-growing country in the G7 apart from North America. She also mentioned confusion. I think that she and her party are the ones who are confused: they are confused on the question of taxes. We have scored Labour’s tax plans, and they amount to an extra £2,094 over four years for the average person. Labour Members say that they want to grow the economy, and they say that they are pro-business—at least, that is what they tell business people outside the House—but they are putting in place a workers plan, led by their deputy leader, that will impose 70 new regulations on small businesses, far more power for trade unions and day-one rights on employment, and will ban flexible working. It will damage many of the things that make small businesses in this country successful.

Let me end by saying this: if we want a Government who will cut inflation further and grow the economy, we should not increase borrowing and increase taxes like the Labour party.

Finance (No. 2) Bill

Tulip Siddiq Excerpts
Gareth Davies Portrait The Exchequer Secretary to the Treasury (Gareth Davies)
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It is a great pleasure, as always, to see you in the Chair, Mrs Latham. Clause 20 begins the process of introducing legislation for a new type of investment fund—the reserved investor fund, which I will refer to from now on as the RIF. At Budget 2020, the Government announced a review of the UK’s funds regime, covering tax and relevant areas of regulation. The review had an overarching objective to make the UK a more attractive location to set up, manage and administer funds, as well as ensuring that UK investors can access a wide enough range of investment vehicles to suit their needs. In the years since, the Government have made a number of successful reforms. In order to build on these successes, the Government announced at spring Budget 2024 that we would be proceeding with the RIF.

The RIF will fill a gap in the UK’s existing fund offering by creating an onshore alternative to existing non-UK fund vehicles that are commonly used to hold UK real estate. Clause 20 provides a definition of the RIF and provides a power for the Treasury to make detailed tax rules through secondary legislation, consistent with the approach taken when introducing tax rules for other investment funds. A later statutory instrument will set out detailed tax rules for the RIF. The regulations will set out supplementary qualifying conditions for a RIF, entry and exit provisions, and rules that deal with breaches of one or more qualifying conditions.

The UK has a world-leading asset management sector. The RIF will play an important role in supporting that leadership by making the UK a more competitive destination for our fund management industry. Indeed, stakeholders from the financial services industry have already shown considerable support for the RIF. I therefore commend the clause to the Committee.

Tulip Siddiq Portrait Tulip Siddiq (Hampstead and Kilburn) (Lab)
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It is a pleasure to serve on this Committee under your chairmanship, Mrs Latham. I am pleased to respond to clauses 20 to 24 on behalf of the Opposition. Clause 20, as the Minister set out, introduces the necessary powers to set the scope and design of the tax regime and rules for the RIF. Labour welcomes the introduction of the RIF, as it will add to the investment products available here in the UK, particularly for the UK commercial real estate sector. However, the trade bodies representing investment managers and real estate fund managers, the Investment Association and the Association of Real Estate Funds, have raised some concerns that I would like to put to the Minister.

There was a widely held expectation across the sector that RIF would broadly mirror the conditions of the existing authorised contractual schemes, or ACSs, but offer less regulatory supervision, freeing the RIF to become a more flexible investment vehicle for a range of more experienced investors. Due, however, to the Government’s decision to categorise the RIF as an alternative investment fund instead of a special investment fund, the RIF and the ACS will now differ in two key aspects. First, the supply of fund management services will be standard-rated at 20% as opposed to being VAT-exempt, and secondly, an alternative investment fund comes with a requirement to raise capital from a number of investors with a view to investing it in accordance with the defined investment policy for the benefit of those investors. That makes sense for large-scale, open-ended funds with an ongoing investment strategy, but it clearly is not designed for funds that do not have a specified investment objective, such as funds of one, joint ventures, co-investment vehicles and acquisition vehicles, which instead were created for a particular purpose such as repackaging and selling existing assets to new markets. Since they do not exist to raise additional capital, the requirements associated with alternative investment funds risk being an unnecessary burden and disproportionate when applied to the RIF.

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Gareth Davies Portrait Gareth Davies
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I am always grateful to see the hon. Member for Hampstead and Kilburn in her place in opposition in these forums, and I appreciate her comments. I will first set out the background to the establishment of the RIF, which was based on significant consultation with industry to fill a specific gap for an unauthorised, contractual-based vehicle. As such, it was based on specific feedback from the industry. The hon. Lady asked a very reasonable question about classification of the fund, and I can tell her that that was considered to be part of the consultation, but in the end we decided to proceed with the structure that we have gone with in the legislation. However, we will of course keep that under review and continue to engage with stakeholders, and we will issue a report on the progress of the RIF in due course. Although we have not established it in the way that some may have wished us to, it is based on consultation and will be reviewed in due course.

Tulip Siddiq Portrait Tulip Siddiq
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I thank the Minister for his response. He said that he considered the options and decided to proceed with it as an alternative investment fund, but he did not actually set out the reasons why. Was there any reason why he decided that it made more sense to do that as opposed to a special investment fund, especially in line with the international comparisons that I gave?

Gareth Davies Portrait Gareth Davies
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This is designed specifically to fill a gap that was previously or currently filled by things such as Jersey property investment trusts. Where there are unauthorised, contractual-based schemes, we do not currently have a vehicle that fills that gap. What we are introducing with the RIF fills that gap and satisfies a vast amount of stakeholders who fed into the consultation, and we are proceeding with that today.

Question put and agreed to.

Clause 20 accordingly ordered to stand part of the Bill.

Clause 21

Economic crime (anti-money laundering) levy

Question proposed, That the clause stand part of the Bill.

Gareth Davies Portrait Gareth Davies
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Clause 21 increases the economic anti-money laundering levy for very large firms, meaning firms regulated for anti-money laundering purposes and which have UK revenue greater than £1 billion per annum. The charge for very large firms increased from £250,000 to £500,000 with effect from 1 April 2024. There is no change to the charge for firms with revenue below £1 billion per annum. The levy was introduced in the 2022-23 tax year as a source of sustainable funding for measures to tackle economic crime and support the delivery of the Government’s commitments contained in the economic crime plan 2. The Government made it clear during the public consultation that levy charges may be adjusted periodically in response to new information, inflation or under-collection. The adjustment is made in response to receipts falling short of the levy’s stated £100 million revenue target.

The clause amends part 3 of the Finance Act 2022 to replace the current charge for very large firms with the new charge of £500,000 per annum. The change will impact an estimated 100 to 110 very large firms across the anti-money laundering regulated sector including, but not limited to, financial services, legal and accountancy firms.

No other aspects of the levy’s calculation or operation are changing and we therefore anticipate administrative impacts on affected firms to be negligible. This adjustment to the economic crime levy for the largest firms will put funding for measures to tackle economic crime on a sustainable footing, helping to protect UK citizens and make the UK a safer place to do business. Only the very largest firms will pay more and burdens will remain low. I commend the clause to the Committee.

Tulip Siddiq Portrait Tulip Siddiq
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We support the measures in clause 21 to raise the funds needed to tackle money laundering, fraud and other types of economic crime, but I cannot ignore the fact that the Government’s efforts to tackle economic crime have been a complete failure. Fraud and scams, for example, have rocketed under this Government, with at least £7.3 billion stolen directly from consumer bank accounts in the UK through fraud last year alone.

Last year, the Government published their fraud strategy to widespread criticism from industry for largely rebadging old measures and re-announcing existing national teams, such as the re-announcement on the replacement of Action Fraud from 2022. The consensus from experts in the industry is that the measures in the strategy will not significantly move the dial, as they do not establish a regulatory framework for tech companies and telcos to participate in the fight against fraud, including through data-sharing with financial services firms and enforcement agencies to enhance detection and prevention measures.

UK Finance, for example, has stated that it is increasingly difficult to understand the imbalance between the financial services sector’s contribution through the levy and that of other sectors that do not contribute but are known to be introducing risk into the same system. We also know that most scams originate on social media or via telecommunications networks yet those sectors do not face the same obligations regarding contributions, nor do they compensate victims defrauded through their platforms. Does the Minister agree with UK Finance? Does he accept that until the Government find a way to bring the tech giants to the table, efforts to tackle fraud and scams will continue to fail?

UK Finance has also raised concerns about the transparency of the levy and reporting on economic crime. On reporting for anti-money laundering purposes, I have heard from numerous City firms that, despite frequent requests, they receive little granular feedback on the impact their reports make. Does the Minister agree that better feedback and wider publicity around successes could help AML-regulated firms to see the value and importance of work in this area more clearly, keeping it at the forefront of their minds? What are the Government doing to ensure that happens?

Drew Hendry Portrait Drew Hendry
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This is a welcome move in principle and in targeting economic crime, but I would agree with the comments we have just heard—this does not shift things in the way that they need to be shifted in order to deal with the issue. It does not seriously tackle online crime, which is relatively rampant, with people being conned and funds being taken illegally. It does not really do much for fraud and economic crime and fails to tackle issues such as money laundering. There has still not been enough action on limited partnerships, for example, which continue to allow unknown individuals to funnel money through those mechanisms. Why are the Government not taking this issue more seriously than through these minor actions in the Bill?

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Tulip Siddiq Portrait Tulip Siddiq
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We believe that individuals or companies generating wealth in the UK should pay their fair share, so we are in complete support of the aims of this clause. However, we have heard concerns raised by the Chartered Institute of Taxation about the effectiveness of the Government’s proposals and I would be interested to hear the Minister’s views on those concerns.

First, the Chartered Institute of Taxation has argued that the clause adds complexity to the tax system, because it uses income tax legislation to tackle perceived corporate tax avoidance. Clause 22 extends provision within the Income Tax Act 2007 to cover avoidance of any tax through transfer made by a closely held company. Could the Minister explain the thinking behind the Government’s decision to tackle corporate tax avoidance in this way, rather than through the corporate tax regime? Does he agree with the Chartered Institute of Taxation that it could add unnecessary complication to the tax system?

Secondly, the Chartered Institute of Taxation made the case that the Government’s position that any participator in a company is deemed to be involved in a company’s decision to move assets abroad is unfair. For example, a company may have several minority shareholders who have no participation in the running of the company. What is the Minister’s assessment of the case made by the Chartered Institute of Taxation that only major shareholders, directors and shadow directors should be assumed to be involved for the purposes of this legislation?

Thirdly, the Chartered Institute of Taxation has warned that these changes could damage the UK’s international competitiveness, because the test as set out in the legislation leaves too much discretion to HMRC, which compounds uncertainty for businesses. For example, a UK holding company that provides a loan to an offshore subsidiary that in turn generates profits could be caught by the changes, despite that being a routine transaction. The Chartered Institute of Taxation argues that that could lead to an increased number of inquiries and appeals to the tax tribunals and could seriously undermine the UK’s attractiveness for international headquarters.

What does the Minister make of those concerns? What steps will HMRC take to ensure that involvement and objection defences under the clause are not ambiguous or uncertain, and to ensure that those charges do not prove to be increased excessively for taxpayers?

My final point is that the changes introduced by clause 22 appear to be retrospective, as no date is specified whereafter transactions are affected; the clause says only that income arising after April 2024 is caught by the regime. Can the Minister confirm whether that is the case? Will commercial transactions that were carried out many years ago, but from which income arises after April 2024, still be caught?

Nigel Huddleston Portrait Nigel Huddleston
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I thank the hon. Member for Hampstead and Kilburn for her comments. We very much appreciate the input that we have received from stakeholders and interested parties, including the Chartered Institute of Taxation. Some of those points are about broader issues around the TOAA regime, rather than specific to this legislation, but we do hear what they have to say.

I will respond to the hon. Lady’s points about the changes that apply to companies when the TOAA regime is primarily about individuals. The transfer of assets abroad legislation is an anti-avoidance provision aimed at preventing individuals from avoiding a tax charge by transferring an asset to a person overseas while still being able to enjoy the income of that asset in some way. It would be easy for an individual to sidestep the legislation by transferring such an asset to a company that they controlled before the company then made the transfer abroad. The legislative changes are aimed at preventing that situation and ensuring that the TOAA rules are applied as intended.

On the point about the legislation being broad, let us not forget that it is being brought in in response to the Supreme Court judgment; we are trying to make sure that it acts as intended throughout. The intention of the legislation is to put the situation involving transfers by companies back to how HMRC considered it operated before the Supreme Court decision. The transfer of assets abroad legislation aims to stop that tax avoidance.

It is also important to remember that the legislation does not bring a tax charge when the transfer is for genuine commercial reasons or when tax avoidance was not the purpose of the transfer. The new legislation gives individuals the opportunity to exclude themselves from the tax charge if certain conditions are met. We respectfully disagree with the CIOT on some of those conditions. We have outlined some of those, and HMRC will produce further guidance in due course.

On the retroactive criticism, the clause has retroactive effect because if it did not, it would have allowed individuals to abuse the loophole between the date of the Fisher judgment and the enactment of the legislation. Again, we do not believe that there will be a significant increase in complexity. The purpose behind the legislation is primarily to ensure that the regime acts as intended.

I will not go into the weeds on HMRC’s determination process—further guidance will be given—but HMRC will review the facts of a case to judge whether someone is directly or indirectly involved in the decision making of a company. It will accept evidence that shows whether someone is involved or not. However, any arrangements that are put in place purely to be used as evidence that an individual is not involved in the decision making of a company will be disregarded and a charge will be levied if the other conditions are met. As I said, HMRC will issue guidance on how it will approach the matter in due course. Decisions will be made based on the facts of each individual case.

I hope that I have given the hon. Member for Hampstead and Kilburn some assurance. We appreciate the concerns that have raised by key stakeholders, and further information and guidance will be forthcoming.

Question put and agreed to.

Clause 22 accordingly ordered to stand part of the Bill.

Clause 23

Minor VAT amendments

Question proposed, That the clause stand part of the Bill.

Nigel Huddleston Portrait Nigel Huddleston
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Clause 23 makes some minor, technical changes to VAT legislation relating to the DIY house builders’ scheme and VAT credit in the penalty reform regime, and allows for reform of the VAT terminal markets order. I will speak briefly about each measure in turn.

The DIY house builders’ scheme allows individuals building their own home, or converting a non-residential building to their own home, to recover VAT incurred on the cost. That puts individual house builders in the same position as property developers, who are able to sell new build residential property at a zero rate and recover the VAT they incur in the process of constructing new build properties. The scheme was simplified and made digital in December last year, which has significantly reduced the time taken for claims to be paid. Under the new process, only essential details are required on the claim form, eliminating the need for claimants to submit certain evidential documents up front. Based on the information provided on the claim form, HMRC can then request evidential documents to verify the claim.

Clause 23(1) will give HMRC a clear power under the DIY house builders’ scheme to require further evidential documentation, such as invoices, from the person who submitted a claim under the scheme. That will assist HMRC in verifying claims.

Clause 23(3) is a minor update to the existing powers that allow for reform of the VAT terminal markets order. The order reduces VAT administration burdens on commodities traded on specified markets, so the power will allow for simplifications to support businesses trading those commodities. The Government previously announced their intention to reform the order to reflect current market practices and to keep pace with market changes, such as trades in new products, including carbon credits. This clause takes that commitment forward.

Finally, subsections (4) and (5) make changes to ensure that VAT interest rules operate as intended. For most major taxes, the Finance Act 2009 requires HMRC to pay interest on amounts due from HMRC to taxpayers, and to charge interest on late payments to HMRC. Historically, that regime did not apply to VAT, which had its own interest rules. Harmonising the rules on interest was an important step in delivering the Government’s ambition to build a trusted, modern tax administration system. Changes made by the Finance Act 2021 brought VAT interest in line with taxes such as income tax from 1 January last year. In implementing the new interest rules for VAT, HMRC has discovered some minor defects in the legislation, which without correction would force it to act in a way that conflicts with policy intent.

Clause 23 will therefore make two changes to the interest rules. The first will address the situation in which interest ought to be repaid to HMRC because, following an assessment or amendment that reduces the amount of VAT credit, the repayment interest due is also reduced. It was always intended that HMRC could recover all these amounts through a simple automated process that does not add to burdens for taxpayers and HMRC alike. The IT system can already operate, but the legislation, mistakenly, does not always allow that automated recovery. The change will ensure that HMRC can do so in all cases instead of needing a different, onerous process for a minority of cases that the original legislation did not cover.

The second change will make sure that VAT-registered businesses are always protected by a provision that creates a fairer basis for the calculation of interest where they owed money to HMRC over the same time that HMRC owed money to them. The original legislation failed to extend that safeguard to all scenarios in which that could happen with VAT, undermining the fairness of the interest regime. To ensure that all VAT-registered businesses are treated equally, the changes will be given backdated effect to 1 January 2023, when the interest rules were introduced for VAT.

Clause 23 makes some small changes to ensure that policy works as intended and to further Government commitments on reforming the VAT terminal markets order. I commend it to the Committee.

Tulip Siddiq Portrait Tulip Siddiq
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The Opposition support the changes that will assist with compliance checks by making online applications equivalent to paper applications. Has the Minister considered adding the online application as a service to the agent services accounts so that an agent can prepare and submit the claim on behalf of their client?

We also support the provisions for modifying the application of VAT for terminal markets, as that will allow for further reforms such as bringing trades in carbon credits within the scope of the Value Added Tax (Terminal Markets) Order. We feel that is a vital and necessary step in developing this important market.

We support the changes to legislation that governs the interaction between late payment interest and repayment interest for VAT. Has the Minister given any thought to reinstating HMRC’s ability not to charge interest on VAT errors where the supplier did not charge VAT, with no loss to the Exchequer because the customer could claim in full?

Drew Hendry Portrait Drew Hendry
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On clause 23’s minor VAT amendments, there is very little to disagree with. VAT should be paid where it is due, and HMRC should pay interest where it should pay interest. That is to be welcomed.

However, on Second Reading I pointed out the paucity of thought and imagination that had gone into providing real help for people across the nations of the UK, and the kinds of thing that the Government could have done but have not. The clause title, “Minor VAT amendments”, just highlights the problem with the entire Bill. The Government could have taken some action to deal with the issues for people in hospitality by cutting VAT and doing something meaningful for tourism, but no: they have chosen to make these minor adjustments. They could have used VAT as a mechanism for helping our high streets to create economic zones that could boost life back into vital high streets and centres. Instead, they have taken to tinkering with the VAT rules.

My question to the Minister is why there is such a lack of ambition in his Government. Is it that this is a fag-end Government in a fag-end Parliament that has run out of ideas, or is it just that they do not care?

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Nigel Huddleston Portrait Nigel Huddleston
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Clause 24 makes further provision for collective money purchase arrangements. CMP arrangements are a new type of pension that have the benefit of pooling individuals’ pension pots to provide better incomes in retirement while limiting the liability of employers.

These changes will enable the Government to authorise the transfer of benefits to a member’s beneficiaries, such as their dependants, in the unlikely event that a member dies while a CMP arrangement is being wound up. That will ensure that such transfers do not incur an unauthorised payment charge of 55%, and it will deliver the Government’s commitment to provide the correct tax outcome for CMP arrangements.

The Pension Schemes Act 2021 introduced legislation to allow collective money purchase schemes to operate in the United Kingdom. This measure authorises the transfer of survivor benefits in collective money purchase pension schemes. This will ensure that Royal Mail Group, the first provider of a collective money purchase pension scheme, can launch its scheme as planned.

It is a complicated title, but with a simple purpose. As a result of these changes, an employee of Royal Mail will be able to sign on to a CMP, with all the benefits, without the risk of transferring survivor benefits being put through as unauthorised transactions. I therefore commend the clause to the Committee.

Tulip Siddiq Portrait Tulip Siddiq
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This clause is so uncontroversial that we give it our full support. For the first time, I agree with everything the Minister has said, and the Committee will be happy to know that I have no further questions for him.

Question put and agreed to.

Clause 24 accordingly ordered to stand part of the Bill.

Clause 25

Interpretation

Question proposed, That the clause stand part of the Bill.

Nigel Huddleston Portrait Nigel Huddleston
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I will be very brief, because the clause is fairly straightforward. It provides for the use of abbreviations for a variety of Acts. For example, it provides for the use of “CTA 2009” as an abbreviation for the Corporation Tax Act 2009. I commend the clause to the Committee.

Question put and agreed to.

Clause 25 accordingly ordered to stand part of the Bill.

Clause 26

Short title

Question proposed, That the clause stand part of the Bill.

Finance (No. 2) Bill (Except clauses 1 to 4, 12 and 13, and 19)

Tulip Siddiq Excerpts
Tuesday 21st May 2024

(3 weeks, 4 days ago)

Public Bill Committees
Read Full debate Read Hansard Text Read Debate Ministerial Extracts
Gareth Davies Portrait The Exchequer Secretary to the Treasury (Gareth Davies)
- Hansard - - - Excerpts

It is a great pleasure, as always, to see you in the Chair, Mrs Latham. Clause 20 begins the process of introducing legislation for a new type of investment fund—the reserved investor fund, which I will refer to from now on as the RIF. At Budget 2020, the Government announced a review of the UK’s funds regime, covering tax and relevant areas of regulation. The review had an overarching objective to make the UK a more attractive location to set up, manage and administer funds, as well as ensuring that UK investors can access a wide enough range of investment vehicles to suit their needs. In the years since, the Government have made a number of successful reforms. In order to build on these successes, the Government announced at spring Budget 2024 that we would be proceeding with the RIF.

The RIF will fill a gap in the UK’s existing fund offering by creating an onshore alternative to existing non-UK fund vehicles that are commonly used to hold UK real estate. Clause 20 provides a definition of the RIF and provides a power for the Treasury to make detailed tax rules through secondary legislation, consistent with the approach taken when introducing tax rules for other investment funds. A later statutory instrument will set out detailed tax rules for the RIF. The regulations will set out supplementary qualifying conditions for a RIF, entry and exit provisions, and rules that deal with breaches of one or more qualifying conditions.

The UK has a world-leading asset management sector. The RIF will play an important role in supporting that leadership by making the UK a more competitive destination for our fund management industry. Indeed, stakeholders from the financial services industry have already shown considerable support for the RIF. I therefore commend the clause to the Committee.

Tulip Siddiq Portrait Tulip Siddiq (Hampstead and Kilburn) (Lab)
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It is a pleasure to serve on this Committee under your chairmanship, Mrs Latham. I am pleased to respond to clauses 20 to 24 on behalf of the Opposition. Clause 20, as the Minister set out, introduces the necessary powers to set the scope and design of the tax regime and rules for the RIF. Labour welcomes the introduction of the RIF, as it will add to the investment products available here in the UK, particularly for the UK commercial real estate sector. However, the trade bodies representing investment managers and real estate fund managers, the Investment Association and the Association of Real Estate Funds, have raised some concerns that I would like to put to the Minister.

There was a widely held expectation across the sector that RIF would broadly mirror the conditions of the existing authorised contractual schemes, or ACSs, but offer less regulatory supervision, freeing the RIF to become a more flexible investment vehicle for a range of more experienced investors. Due, however, to the Government’s decision to categorise the RIF as an alternative investment fund instead of a special investment fund, the RIF and the ACS will now differ in two key aspects. First, the supply of fund management services will be standard-rated at 20% as opposed to being VAT-exempt, and secondly, an alternative investment fund comes with a requirement to raise capital from a number of investors with a view to investing it in accordance with the defined investment policy for the benefit of those investors. That makes sense for large-scale, open-ended funds with an ongoing investment strategy, but it clearly is not designed for funds that do not have a specified investment objective, such as funds of one, joint ventures, co-investment vehicles and acquisition vehicles, which instead were created for a particular purpose such as repackaging and selling existing assets to new markets. Since they do not exist to raise additional capital, the requirements associated with alternative investment funds risk being an unnecessary burden and disproportionate when applied to the RIF.

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Gareth Davies Portrait Gareth Davies
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I am always grateful to see the hon. Member for Hampstead and Kilburn in her place in opposition in these forums, and I appreciate her comments. I will first set out the background to the establishment of the RIF, which was based on significant consultation with industry to fill a specific gap for an unauthorised, contractual-based vehicle. As such, it was based on specific feedback from the industry. The hon. Lady asked a very reasonable question about classification of the fund, and I can tell her that that was considered to be part of the consultation, but in the end we decided to proceed with the structure that we have gone with in the legislation. However, we will of course keep that under review and continue to engage with stakeholders, and we will issue a report on the progress of the RIF in due course. Although we have not established it in the way that some may have wished us to, it is based on consultation and will be reviewed in due course.

Tulip Siddiq Portrait Tulip Siddiq
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I thank the Minister for his response. He said that he considered the options and decided to proceed with it as an alternative investment fund, but he did not actually set out the reasons why. Was there any reason why he decided that it made more sense to do that as opposed to a special investment fund, especially in line with the international comparisons that I gave?

Gareth Davies Portrait Gareth Davies
- Hansard - - - Excerpts

This is designed specifically to fill a gap that was previously or currently filled by things such as Jersey property investment trusts. Where there are unauthorised, contractual-based schemes, we do not currently have a vehicle that fills that gap. What we are introducing with the RIF fills that gap and satisfies a vast amount of stakeholders who fed into the consultation, and we are proceeding with that today.

Question put and agreed to.

Clause 20 accordingly ordered to stand part of the Bill.

Clause 21

Economic crime (anti-money laundering) levy

Question proposed, That the clause stand part of the Bill.

Gareth Davies Portrait Gareth Davies
- Hansard - - - Excerpts

Clause 21 increases the economic anti-money laundering levy for very large firms, meaning firms regulated for anti-money laundering purposes and which have UK revenue greater than £1 billion per annum. The charge for very large firms increased from £250,000 to £500,000 with effect from 1 April 2024. There is no change to the charge for firms with revenue below £1 billion per annum. The levy was introduced in the 2022-23 tax year as a source of sustainable funding for measures to tackle economic crime and support the delivery of the Government’s commitments contained in the economic crime plan 2. The Government made it clear during the public consultation that levy charges may be adjusted periodically in response to new information, inflation or under-collection. The adjustment is made in response to receipts falling short of the levy’s stated £100 million revenue target.

The clause amends part 3 of the Finance Act 2022 to replace the current charge for very large firms with the new charge of £500,000 per annum. The change will impact an estimated 100 to 110 very large firms across the anti-money laundering regulated sector including, but not limited to, financial services, legal and accountancy firms.

No other aspects of the levy’s calculation or operation are changing and we therefore anticipate administrative impacts on affected firms to be negligible. This adjustment to the economic crime levy for the largest firms will put funding for measures to tackle economic crime on a sustainable footing, helping to protect UK citizens and make the UK a safer place to do business. Only the very largest firms will pay more and burdens will remain low. I commend the clause to the Committee.

Tulip Siddiq Portrait Tulip Siddiq
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We support the measures in clause 21 to raise the funds needed to tackle money laundering, fraud and other types of economic crime, but I cannot ignore the fact that the Government’s efforts to tackle economic crime have been a complete failure. Fraud and scams, for example, have rocketed under this Government, with at least £7.3 billion stolen directly from consumer bank accounts in the UK through fraud last year alone.

Last year, the Government published their fraud strategy to widespread criticism from industry for largely rebadging old measures and re-announcing existing national teams, such as the re-announcement on the replacement of Action Fraud from 2022. The consensus from experts in the industry is that the measures in the strategy will not significantly move the dial, as they do not establish a regulatory framework for tech companies and telcos to participate in the fight against fraud, including through data-sharing with financial services firms and enforcement agencies to enhance detection and prevention measures.

UK Finance, for example, has stated that it is increasingly difficult to understand the imbalance between the financial services sector’s contribution through the levy and that of other sectors that do not contribute but are known to be introducing risk into the same system. We also know that most scams originate on social media or via telecommunications networks yet those sectors do not face the same obligations regarding contributions, nor do they compensate victims defrauded through their platforms. Does the Minister agree with UK Finance? Does he accept that until the Government find a way to bring the tech giants to the table, efforts to tackle fraud and scams will continue to fail?

UK Finance has also raised concerns about the transparency of the levy and reporting on economic crime. On reporting for anti-money laundering purposes, I have heard from numerous City firms that, despite frequent requests, they receive little granular feedback on the impact their reports make. Does the Minister agree that better feedback and wider publicity around successes could help AML-regulated firms to see the value and importance of work in this area more clearly, keeping it at the forefront of their minds? What are the Government doing to ensure that happens?

Drew Hendry Portrait Drew Hendry
- Hansard - - - Excerpts

This is a welcome move in principle and in targeting economic crime, but I would agree with the comments we have just heard—this does not shift things in the way that they need to be shifted in order to deal with the issue. It does not seriously tackle online crime, which is relatively rampant, with people being conned and funds being taken illegally. It does not really do much for fraud and economic crime and fails to tackle issues such as money laundering. There has still not been enough action on limited partnerships, for example, which continue to allow unknown individuals to funnel money through those mechanisms. Why are the Government not taking this issue more seriously than through these minor actions in the Bill?

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Tulip Siddiq Portrait Tulip Siddiq
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We believe that individuals or companies generating wealth in the UK should pay their fair share, so we are in complete support of the aims of this clause. However, we have heard concerns raised by the Chartered Institute of Taxation about the effectiveness of the Government’s proposals and I would be interested to hear the Minister’s views on those concerns.

First, the Chartered Institute of Taxation has argued that the clause adds complexity to the tax system, because it uses income tax legislation to tackle perceived corporate tax avoidance. Clause 22 extends provision within the Income Tax Act 2007 to cover avoidance of any tax through transfer made by a closely held company. Could the Minister explain the thinking behind the Government’s decision to tackle corporate tax avoidance in this way, rather than through the corporate tax regime? Does he agree with the Chartered Institute of Taxation that it could add unnecessary complication to the tax system?

Secondly, the Chartered Institute of Taxation made the case that the Government’s position that any participator in a company is deemed to be involved in a company’s decision to move assets abroad is unfair. For example, a company may have several minority shareholders who have no participation in the running of the company. What is the Minister’s assessment of the case made by the Chartered Institute of Taxation that only major shareholders, directors and shadow directors should be assumed to be involved for the purposes of this legislation?

Thirdly, the Chartered Institute of Taxation has warned that these changes could damage the UK’s international competitiveness, because the test as set out in the legislation leaves too much discretion to HMRC, which compounds uncertainty for businesses. For example, a UK holding company that provides a loan to an offshore subsidiary that in turn generates profits could be caught by the changes, despite that being a routine transaction. The Chartered Institute of Taxation argues that that could lead to an increased number of inquiries and appeals to the tax tribunals and could seriously undermine the UK’s attractiveness for international headquarters.

What does the Minister make of those concerns? What steps will HMRC take to ensure that involvement and objection defences under the clause are not ambiguous or uncertain, and to ensure that those charges do not prove to be increased excessively for taxpayers?

My final point is that the changes introduced by clause 22 appear to be retrospective, as no date is specified whereafter transactions are affected; the clause says only that income arising after April 2024 is caught by the regime. Can the Minister confirm whether that is the case? Will commercial transactions that were carried out many years ago, but from which income arises after April 2024, still be caught?

Nigel Huddleston Portrait Nigel Huddleston
- Hansard - - - Excerpts

I thank the hon. Member for Hampstead and Kilburn for her comments. We very much appreciate the input that we have received from stakeholders and interested parties, including the Chartered Institute of Taxation. Some of those points are about broader issues around the TOAA regime, rather than specific to this legislation, but we do hear what they have to say.

I will respond to the hon. Lady’s points about the changes that apply to companies when the TOAA regime is primarily about individuals. The transfer of assets abroad legislation is an anti-avoidance provision aimed at preventing individuals from avoiding a tax charge by transferring an asset to a person overseas while still being able to enjoy the income of that asset in some way. It would be easy for an individual to sidestep the legislation by transferring such an asset to a company that they controlled before the company then made the transfer abroad. The legislative changes are aimed at preventing that situation and ensuring that the TOAA rules are applied as intended.

On the point about the legislation being broad, let us not forget that it is being brought in in response to the Supreme Court judgment; we are trying to make sure that it acts as intended throughout. The intention of the legislation is to put the situation involving transfers by companies back to how HMRC considered it operated before the Supreme Court decision. The transfer of assets abroad legislation aims to stop that tax avoidance.

It is also important to remember that the legislation does not bring a tax charge when the transfer is for genuine commercial reasons or when tax avoidance was not the purpose of the transfer. The new legislation gives individuals the opportunity to exclude themselves from the tax charge if certain conditions are met. We respectfully disagree with the CIOT on some of those conditions. We have outlined some of those, and HMRC will produce further guidance in due course.

On the retroactive criticism, the clause has retroactive effect because if it did not, it would have allowed individuals to abuse the loophole between the date of the Fisher judgment and the enactment of the legislation. Again, we do not believe that there will be a significant increase in complexity. The purpose behind the legislation is primarily to ensure that the regime acts as intended.

I will not go into the weeds on HMRC’s determination process—further guidance will be given—but HMRC will review the facts of a case to judge whether someone is directly or indirectly involved in the decision making of a company. It will accept evidence that shows whether someone is involved or not. However, any arrangements that are put in place purely to be used as evidence that an individual is not involved in the decision making of a company will be disregarded and a charge will be levied if the other conditions are met. As I said, HMRC will issue guidance on how it will approach the matter in due course. Decisions will be made based on the facts of each individual case.

I hope that I have given the hon. Member for Hampstead and Kilburn some assurance. We appreciate the concerns that have raised by key stakeholders, and further information and guidance will be forthcoming.

Question put and agreed to.

Clause 22 accordingly ordered to stand part of the Bill.

Clause 23

Minor VAT amendments

Question proposed, That the clause stand part of the Bill.

Nigel Huddleston Portrait Nigel Huddleston
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Clause 23 makes some minor, technical changes to VAT legislation relating to the DIY house builders’ scheme and VAT credit in the penalty reform regime, and allows for reform of the VAT terminal markets order. I will speak briefly about each measure in turn.

The DIY house builders’ scheme allows individuals building their own home, or converting a non-residential building to their own home, to recover VAT incurred on the cost. That puts individual house builders in the same position as property developers, who are able to sell new build residential property at a zero rate and recover the VAT they incur in the process of constructing new build properties. The scheme was simplified and made digital in December last year, which has significantly reduced the time taken for claims to be paid. Under the new process, only essential details are required on the claim form, eliminating the need for claimants to submit certain evidential documents up front. Based on the information provided on the claim form, HMRC can then request evidential documents to verify the claim.

Clause 23(1) will give HMRC a clear power under the DIY house builders’ scheme to require further evidential documentation, such as invoices, from the person who submitted a claim under the scheme. That will assist HMRC in verifying claims.

Clause 23(3) is a minor update to the existing powers that allow for reform of the VAT terminal markets order. The order reduces VAT administration burdens on commodities traded on specified markets, so the power will allow for simplifications to support businesses trading those commodities. The Government previously announced their intention to reform the order to reflect current market practices and to keep pace with market changes, such as trades in new products, including carbon credits. This clause takes that commitment forward.

Finally, subsections (4) and (5) make changes to ensure that VAT interest rules operate as intended. For most major taxes, the Finance Act 2009 requires HMRC to pay interest on amounts due from HMRC to taxpayers, and to charge interest on late payments to HMRC. Historically, that regime did not apply to VAT, which had its own interest rules. Harmonising the rules on interest was an important step in delivering the Government’s ambition to build a trusted, modern tax administration system. Changes made by the Finance Act 2021 brought VAT interest in line with taxes such as income tax from 1 January last year. In implementing the new interest rules for VAT, HMRC has discovered some minor defects in the legislation, which without correction would force it to act in a way that conflicts with policy intent.

Clause 23 will therefore make two changes to the interest rules. The first will address the situation in which interest ought to be repaid to HMRC because, following an assessment or amendment that reduces the amount of VAT credit, the repayment interest due is also reduced. It was always intended that HMRC could recover all these amounts through a simple automated process that does not add to burdens for taxpayers and HMRC alike. The IT system can already operate, but the legislation, mistakenly, does not always allow that automated recovery. The change will ensure that HMRC can do so in all cases instead of needing a different, onerous process for a minority of cases that the original legislation did not cover.

The second change will make sure that VAT-registered businesses are always protected by a provision that creates a fairer basis for the calculation of interest where they owed money to HMRC over the same time that HMRC owed money to them. The original legislation failed to extend that safeguard to all scenarios in which that could happen with VAT, undermining the fairness of the interest regime. To ensure that all VAT-registered businesses are treated equally, the changes will be given backdated effect to 1 January 2023, when the interest rules were introduced for VAT.

Clause 23 makes some small changes to ensure that policy works as intended and to further Government commitments on reforming the VAT terminal markets order. I commend it to the Committee.

Tulip Siddiq Portrait Tulip Siddiq
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The Opposition support the changes that will assist with compliance checks by making online applications equivalent to paper applications. Has the Minister considered adding the online application as a service to the agent services accounts so that an agent can prepare and submit the claim on behalf of their client?

We also support the provisions for modifying the application of VAT for terminal markets, as that will allow for further reforms such as bringing trades in carbon credits within the scope of the Value Added Tax (Terminal Markets) Order. We feel that is a vital and necessary step in developing this important market.

We support the changes to legislation that governs the interaction between late payment interest and repayment interest for VAT. Has the Minister given any thought to reinstating HMRC’s ability not to charge interest on VAT errors where the supplier did not charge VAT, with no loss to the Exchequer because the customer could claim in full?

Drew Hendry Portrait Drew Hendry
- Hansard - - - Excerpts

On clause 23’s minor VAT amendments, there is very little to disagree with. VAT should be paid where it is due, and HMRC should pay interest where it should pay interest. That is to be welcomed.

However, on Second Reading I pointed out the paucity of thought and imagination that had gone into providing real help for people across the nations of the UK, and the kinds of thing that the Government could have done but have not. The clause title, “Minor VAT amendments”, just highlights the problem with the entire Bill. The Government could have taken some action to deal with the issues for people in hospitality by cutting VAT and doing something meaningful for tourism, but no: they have chosen to make these minor adjustments. They could have used VAT as a mechanism for helping our high streets to create economic zones that could boost life back into vital high streets and centres. Instead, they have taken to tinkering with the VAT rules.

My question to the Minister is why there is such a lack of ambition in his Government. Is it that this is a fag-end Government in a fag-end Parliament that has run out of ideas, or is it just that they do not care?

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Nigel Huddleston Portrait Nigel Huddleston
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Clause 24 makes further provision for collective money purchase arrangements. CMP arrangements are a new type of pension that have the benefit of pooling individuals’ pension pots to provide better incomes in retirement while limiting the liability of employers.

These changes will enable the Government to authorise the transfer of benefits to a member’s beneficiaries, such as their dependants, in the unlikely event that a member dies while a CMP arrangement is being wound up. That will ensure that such transfers do not incur an unauthorised payment charge of 55%, and it will deliver the Government’s commitment to provide the correct tax outcome for CMP arrangements.

The Pension Schemes Act 2021 introduced legislation to allow collective money purchase schemes to operate in the United Kingdom. This measure authorises the transfer of survivor benefits in collective money purchase pension schemes. This will ensure that Royal Mail Group, the first provider of a collective money purchase pension scheme, can launch its scheme as planned.

It is a complicated title, but with a simple purpose. As a result of these changes, an employee of Royal Mail will be able to sign on to a CMP, with all the benefits, without the risk of transferring survivor benefits being put through as unauthorised transactions. I therefore commend the clause to the Committee.

Tulip Siddiq Portrait Tulip Siddiq
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This clause is so uncontroversial that we give it our full support. For the first time, I agree with everything the Minister has said, and the Committee will be happy to know that I have no further questions for him.

Question put and agreed to.

Clause 24 accordingly ordered to stand part of the Bill.

Clause 25

Interpretation

Question proposed, That the clause stand part of the Bill.

Nigel Huddleston Portrait Nigel Huddleston
- Hansard - - - Excerpts

I will be very brief, because the clause is fairly straightforward. It provides for the use of abbreviations for a variety of Acts. For example, it provides for the use of “CTA 2009” as an abbreviation for the Corporation Tax Act 2009. I commend the clause to the Committee.

Question put and agreed to.

Clause 25 accordingly ordered to stand part of the Bill.

Clause 26

Short title

Question proposed, That the clause stand part of the Bill.

Draft Securitisation (Amendment) Regulations 2024

Tulip Siddiq Excerpts
Tuesday 14th May 2024

(1 month ago)

General Committees
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Tulip Siddiq Portrait Tulip Siddiq (Hampstead and Kilburn) (Lab)
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It is a pleasure to serve under you, Madam Chair. I thank the Minister for setting out the purpose of the statutory instrument before us today, which is complementary to the Securitisation Regulations 2024, which we debated in January. We supported those regulations in January and we will be supporting the ones before us today. We feel that these form part of an important package of reform aimed at developing a securitisation market in our country that contributes to growth in the real economy.

I have a couple of questions, which are based on the specific measures introduced by this SI. I welcome the fact that the PRA listened to our objections during its consultations and restored the existing language to do with confidentiality. However, I am sure the Minister will be aware that the sector still has concerns that the existing language creates some uncertainty. Does the Minister share those concerns, and has he raised the matter with the PRA?

Many of the industry’s concerns regarding risk retention and credit granting were not addressed in the current version of the rules, so will the Treasury be working with regulators to ensure that these concerns are taken into account with future policy developments?

Finally, in terms of next steps, which the Minister did outline, the FCA and the PRA expect to consult on further changes to their securitisation rules in Q4 2024 and Q1 2025. How confident is the Minister that these timelines will be met?

Draft International Monetary Fund (Increase in Subscription) Order 2024

Tulip Siddiq Excerpts
Monday 13th May 2024

(1 month ago)

General Committees
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Tulip Siddiq Portrait Tulip Siddiq (Hampstead and Kilburn) (Lab)
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It is a pleasure to serve under your chairmanship, Sir Graham.

We welcome this draft statutory instrument. The changes are part of the IMF’s worldwide resolution to change its funding model to reduce the level of IMF temporary loan facilities, and will increase the funding provided through the quota system to the same extent, as the Minister explained. We believe that the changes serve to make the IMF stronger and more legitimate, and are key to ensuring economic stability.

The official Opposition are completely committed to such stability, which is underpinned by strong fiscal rules, robust independent institutions—the Treasury, the Bank of England and the Office for Budget Responsibility— and international economic institutions such as the IMF, which promote financial literacy, stability and monetary co-operation. We therefore fully support the proposals and for once, I do not have a host of questions for the Minister.

Question put and agreed to.

Oral Answers to Questions

Tulip Siddiq Excerpts
Tuesday 7th May 2024

(1 month, 1 week ago)

Commons Chamber
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Lindsay Hoyle Portrait Mr Speaker
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I call the shadow Minister.

Tulip Siddiq Portrait Tulip Siddiq (Hampstead and Kilburn) (Lab)
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Since 2022, almost 400 communities have lost their local bank branch, which has had a devastating impact on local and small businesses. Despite witnessing the decline of the British high street, the Government have been dragging their feet on rolling out banking hubs, which would help local and small businesses. Will the Minister finally back the Labour party’s plans to provide a banking hub in every community that needs one?

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Bim Afolami Portrait Bim Afolami
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I am happy to meet my right hon. Friend to discuss the lifetime ISA, which is a fantastic product brought in by this Government to help young people to get on the housing ladder. I am happy to meet him to discuss ways in which we can make it more accessible for more people in more circumstances.

Tulip Siddiq Portrait Tulip Siddiq (Hampstead and Kilburn) (Lab)
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On a point of order, Mr Speaker.

Lindsay Hoyle Portrait Mr Speaker
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Is it related to Treasury questions?

Tulip Siddiq Portrait Tulip Siddiq
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Yes. In his response to me, the Exchequer Secretary said, “Any area that loses bank branches is entitled to get a banking hub”, but I have numerous examples of towns that lost bank branches, applied for a banking hub and then had their application rejected. Please could you advise me, Mr Speaker, on how I can get some clarity on this matter and what the Minister said about “any area that loses bank branches”?

Lindsay Hoyle Portrait Mr Speaker
- Hansard - - - Excerpts

Obviously, we cannot continue the debate. The hon. Lady has certainly put her point on the record. I do not think this will be the end of it; she knows how to carry it on through the usual channels, which I expect she will use, no doubt starting with the Table Office.

Finance (No. 2) Bill

Tulip Siddiq Excerpts
2nd reading
Wednesday 17th April 2024

(1 month, 4 weeks ago)

Commons Chamber
Read Full debate Finance Act (No. 2) 2024 2023-24 View all Finance Act (No. 2) 2024 2023-24 Debates Read Hansard Text Watch Debate Read Debate Ministerial Extracts
Tulip Siddiq Portrait Tulip Siddiq (Hampstead and Kilburn) (Lab)
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As my hon. Friend the Member for Ealing North (James Murray) set out in his opening speech, this Finance Bill and last month’s Budget are nothing but the last gasps of a dying, desperate Government. Neither does anything to address 14 years of Conservative economic failure, and as always with this Government, it is working people who pay the price, because taxes are still rising. The British people, already facing the highest tax burden in 70 years, will see tax rises in every single year of the forecast period. As much as the Government try, they simply cannot hide from that record: after a decade and a half of Conservative rule, people have less money in their pockets.

Unable to defend his own Government’s record, and unable to offer any plan to get the country out of the economic mess that his party has created, this Chancellor has resorted to undeliverable promises. The Chancellor ended his Budget last month with a £46 billion unfunded tax plan to abolish national insurance, which would put our economic stability at risk. That is even bigger than the unfunded tax cuts announced by the right hon. Member for South West Norfolk (Elizabeth Truss) in her Budget, which added hundreds of pounds to people’s mortgages.

In contrast, the Labour party has consistently said that we would reduce the tax burden on families. That is why we opposed the current Prime Minister when he wanted to increase national insurance two years ago, and it is why we supported the measures announced last month to bring national insurance down by an additional 2p.

Although on the surface this Bill leaves the basic and higher rates of income tax unchanged, let us be clear: this is a Government who have raised the tax burden to record levels, and taxes are continuing to rise. Because of the tax choices that this Chancellor has made, households will be, on average, £870 worse off. His decision to freeze tax thresholds will create 3.2 million new taxpayers by 2028, and 2.6 million more people will be paying higher rates. For every £5 that the Government are giving back to families, they will be taking an average of £10 in higher taxes under their plans, and they expect the British public to thank them for it.

While we will always call out the Conservatives for pickpocketing the British taxpayer, we do welcome their recent pickpocketing of Labour policies. Labour has long argued that if people make Britain their home, they should pay their taxes here too. However, the Prime Minister himself has said that scrapping the non-dom tax status would somehow end up costing Britain money, and the Chancellor previously tried to argue that the non-dom status supports jobs and that reforming it would damage long-term growth. I am delighted to say that the Prime Minister and the Chancellor have finally come around to the Labour party’s way of thinking, but it is not quite what it seems. I am not denying that Conservative Members have come a long way after years of opposing our plan to scrap the non-dom status, but there are still some gaping loopholes in the Government’s plans.

The discount in year 1 is unnecessary and unjustified, and particularly concerning is the loophole that will allow non-doms to exploit offshore trusts so that they can avoid inheritance tax. As my hon. Friend the Member for Ealing North made clear, these loopholes must be closed. I hope that the Minister, when he responds, will commit to closing these loopholes, so I wait with bated breath to hear what he has to say on this policy. If not, will he accept that the Conservatives are once again putting the interests of non-doms before those of ordinary British taxpayers and British businesses?

Let us take corporation tax, which clause 12 sets at 25%. All this Chancellor has had to offer British businesses is uncertainty. Despite promising to cut corporation tax from 19% to 15% in his 2022 leadership bid, he has increased it from 19% to 25%. In contrast, our shadow Chancellor has committed to capping the headline rate of corporation tax at its current rate for the whole of the next Parliament, and we would take action if tax changes in other advanced economies threatened to undermine UK competitiveness.

The Opposition will be supporting the energy security investment mechanism in clause 19 of the Bill before us, as it will help investors get the confidence they need. Likewise, we are committed both to strengthening the windfall tax to raise more revenue to support our country’s energy transition, and to giving as much certainty as possible to the companies affected. That is why our shadow Chancellor has made it clear that, under Labour, our one-off, time-limited energy profits levy will cease to apply by the end of the next Parliament.

We will not be opposing the Bill today, but we will be looking closely at the detail in the specific clauses in the coming weeks. However, let us be under no illusions: this is an exhausted and directionless Conservative Government who are out of ideas and out of time. All they have to offer are U-turns, unfunded promises and an ever-growing tax burden on working people and our constituents. In contrast, the Labour party’s offer to the country will be carefully costed and fully funded, and we will always put working people and British businesses first.

The Government have failed to reduce the tax burden, failed to boost business investment, and delivered only stagnation and chaos, whereas our economic plan is built on the pillars of stability, investment and reform: stability brought about by iron discipline, and guarded by strong fiscal rules, robust economic institutions and certainty on corporation tax; investment, working with the private sector, so that we can lead the industries of the future and make work pay; and reform, starting with our planning system, to tackle vested interests. The British people deserve better than this. The British people deserve change. I hope the Minister will agree with me that it is now time to call a general election as soon as possible.

Draft Financial Services and Markets Act 2000 (Disapplication or Modification of Financial Regulator Rules in Individual Cases) Regulations 2024

Tulip Siddiq Excerpts
Monday 15th April 2024

(2 months ago)

General Committees
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Tulip Siddiq Portrait Tulip Siddiq (Hampstead and Kilburn) (Lab)
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It is a pleasure to serve with you in the Chair, Mrs Cummins. The Opposition are supportive of the proposed changes, which would enact section 138BA to enable the PRA to more easily adapt, disapply or modify its rules for individual firms.

The greater flexibility the Minister outlined is welcome, but could a similar approach be used to clear the logjam of mid-tier banks wanting to use the internal ratings-based approach? The PRA has helpfully provided some flexibility in relation to IRB model approvals, which could narrow the capital requirements gap between mid-tier and large banks, therefore improving competition in UK banking markets. However, as the Minister may have seen in the Financial Times last August, UK challenger banks have faced multi-year delays to regulatory approvals, which has undermined the potential boost to competition in the market. Has the Treasury given any thought to whether section 138BA could be used to speed up the IRB model approval process for mid-tier banks currently on the standardised approach? I believe—and the Minister may agree—that that could dramatically improve competition in the banking market.

Bim Afolami Portrait Bim Afolami
- Hansard - - - Excerpts

I thank the hon. Lady for her points. In essence, the regulations give the PRA much more flexibility around the entire rulebook to apply to any specific firm. If the question is whether they will give the PRA the ability to change rules in relation to a particular subset of firms, the answer, of course, is yes. However, if the question—she also mentioned this in her remarks—is whether they will somehow speed up or change the pace at which the rules will be made or applied, that is not what they are meant for. So, yes, the regulations will give much more flexibility—and it is a policy question as to whether that is desirable in any particular circumstance—but they do not necessarily increase or decrease the speed at which such rules change.

Tulip Siddiq Portrait Tulip Siddiq
- Hansard - -

I thank the Minister for that answer, and I understand what he is trying to say, but I would like to push this point. If we could speed up the IRB model approvals process for mid-tier banks currently on the standardised approach, that would help our country and the banking market generally, and both sides of the House obviously want to boost competition. I understand that that is not what this particular legislation will do, but have the Minister or the Treasury given any thought to the issue? In the long run, such a change would benefit the financial services sector.

Bim Afolami Portrait Bim Afolami
- Hansard - - - Excerpts

In terms of where I agree with the hon. Lady, I did not just read about this in the Financial Times last year; I have met mid-tier banks, and I understand their challenges. Their concerns are valid, and we need to do everything we can to support that part of the sector. The regulations allow the banks to apply to the FCA in the way that the hon. Lady outlines. That is something that, if appropriate, I would be very happy to support. Yes, it is important that we have competition, but it is also important that we enable every type of business and every type of individual to be appropriately served by our financial services industry, and more firms offering more services in a way that is prudentially safe is positive to that.

Question put and agreed to.

Oral Answers to Questions

Tulip Siddiq Excerpts
Tuesday 19th March 2024

(2 months, 4 weeks ago)

Commons Chamber
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Laura Trott Portrait Laura Trott
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Real wages are now, happily, starting to rise and, as I have said, the OBR has said that inflation will be back to target next quarter. What would not help the cost of living is putting people’s taxes up, as the Scottish Government are doing.

Tulip Siddiq Portrait Tulip Siddiq (Hampstead and Kilburn) (Lab)
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The tax burden is at a record high, wages are stagnant, rents and mortgages are up by hundreds of pounds, and food prices have gone up by 25%. The Resolution Foundation has confirmed that this is the only Parliament on record during which living standards have fallen. Our constituents deserve better. When is the Minister going to give the British public a chance to vote for change and call for a general election?

Laura Trott Portrait Laura Trott
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We have talked a lot today about the £400 billion of support that we put in during the pandemic and the £100 billion of support that we put in to support people during Putin’s energy price shock. The Labour party did not disagree with any of those things, and I think the hon. Lady in her heart of hearts will know that we have to pay for that—at least, I hope she does. We have had to take some difficult decisions, but because of that, the economy is turning a corner. We are able to reduce working people’s taxes, and I hope that she and her party will find it within themselves to support us in that endeavour.

Tulip Siddiq Portrait Tulip Siddiq (Hampstead and Kilburn) (Lab)
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Thank you, Mr Deputy Speaker.

Labour will always support policies that ease the burden on working people. Labour has said consistently that we want taxes on working people to be lower. That is why, two years ago, when the current Prime Minister wanted to increase national insurance, we opposed it. That is why we supported the cut to national insurance last autumn and why we will support these measures we are debating to bring down national insurance by a further 2p. Let us be clear, however, that the measures come in the context of the highest tax burden on working people since 1949—a tax burden that is continuing to rise. The British public face not just further tax rises, but stagnant growth and wages, prices still going up in the shops, and higher mortgages and rents. Indeed, this will be the only Parliament on record in which living standards have fallen.

Unwilling and unable to fix the economic mess that they have created, the Government have resorted to empty promises—pledge after pledge, but never a plan. Last week, the Chancellor made a £46 billion unfunded promise to abolish national insurance altogether, with no explanation of how he would pay for it. I look forward to the Minister explaining in his speech exactly how it will be paid for. The British people are sick and tired of Conservative spin.

Let us take the Government’s claim that a person on average earnings will be £900 better off as result of this national insurance cut, when combined with the changes made in January. That completely ignores the Chancellor’s own stealth tax rises. His decision not to increase tax thresholds in line with inflation means that the tax burden is forecast to rise by another £41.1 billion over the next five years. That fiscal drag will create 3.7 million new taxpayers by 2028-29. OBR figures show that for every 10p extra that working people pay in tax under this plan, they will get back only 5p as result of the combined cuts to national insurance contributions. As usual, the Conservatives give with one hand, and take with the other, and they expect the British public to be grateful.

Paul Johnson, the director of the Institute for Fiscal Studies, said after last week’s Budget that

“this remains a parliament of record tax rises”,

and that is before we consider the rising cost of bills, with food prices up by 25%, rents by 10% and mortgages by an average of £240 a month. Rather than people being £900 better off, as the Conservatives claim, household income is set to fall by £200 over the course of this Parliament.

A week ago, the Chancellor had the opportunity to deliver a Budget that would finally break our country out of the low-growth, low-wage, high-tax cycle that we have been trapped in because of 14 years of economic failure. The British people needed a Budget for the long term to bring prosperity and rebuild our public services, and yet the Chancellor ended his Budget with a £46 billion unfunded tax plan to abolish national insurance. That would leave a gaping hole in the public finances, put family finances at risk and create huge uncertainty for pensioners. I have not heard one attempt from the Government Benches to explain where that money will come from. I look forward to the Minister’s response, because I am sure he will break down exactly where that £46 billion will come from.

Gavin Newlands Portrait Gavin Newlands
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If the measure is so bad, why is the hon. Lady not voting against it?

Tulip Siddiq Portrait Tulip Siddiq
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I will not take any lectures from a party that puts oil and gas companies ahead of working people. If the hon. Member wants to change his policy on oil and gas companies having priority over working people, he can intervene again, but somehow I do not think that it will change.

The last time the Conservatives implemented a proposal like this, just 18 months ago, they crashed the economy. In fact, the Chancellor’s plan to abolish national insurance contributions would cost more per year than the proposals in that disastrous mini-Budget. The Conservatives might deny it, but millions of people are still paying the price of their last ideological experiment: the typical family faces an extra £240 a month when remortgaging this year. The Chancellor’s commitment last week exposed a Conservative Government who are putting party first and country second.

Labour is under no illusions about the state of the public finances after 14 years of Conservative government. We know that if we are elected at the next general election, we will have to take tough decisions in government, but instead of the chaos and recklessness we have seen under the Conservatives, Labour will bring stability and security back to the economy. We will never make a commitment without first saying where the money will come from. We will always be honest with the public because that is the responsible approach.

I hope that the Minister, whom I like very much, will finally come clean with the British people in his response. I hope that he will finally break with his party’s irresponsible promises and endless spin. I hope that he will be honest and say that, as a result of decisions taken by his Government, the tax burden on working people is forecast to go up each year over the next five years, and that for every 10p extra that working people pay in tax under the Conservatives, they will get only 5p back. Most importantly, I hope that he takes the opportunity to be straight with the British people, as we have repeatedly asked him to do, by setting out exactly how his Government will pay for their unfunded £46 billion promise to abolish national insurance.

Kirsty Blackman Portrait Kirsty Blackman
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Will the hon. Lady give way?

Tulip Siddiq Portrait Tulip Siddiq
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No, I am finishing.

The British people deserve better. This is just another Conservative pledge without a plan. The Conservatives should call a general election now.