Asked by: Lord Harries of Pentregarth (Crossbench - Life peer)
Question to the HM Treasury:
To ask Her Majesty’s Government how long it took to agree 50 per cent of Advance Thin Capitalisation Agreements in (1) 2014–15, and (2) 2015–16.
Answered by Baroness Neville-Rolfe - Shadow Minister (Treasury)
HM Revenue and Customs (HMRC) intends to publish Advanced Thin Capitalisation Agreement statistics in due course as part of a wider publication of data relating to HMRC’s work on collecting tax owed to the UK.
Asked by: Lord Harries of Pentregarth (Crossbench - Life peer)
Question to the HM Treasury:
To ask Her Majesty’s Government what was the average time to reach an Advance Thin Capitalisation Agreement in (1) 2014–15, and (2) 2015–16.
Answered by Baroness Neville-Rolfe - Shadow Minister (Treasury)
HM Revenue and Customs (HMRC) intends to publish Advanced Thin Capitalisation Agreement statistics in due course as part of a wider publication of data relating to HMRC’s work on collecting tax owed to the UK.
Asked by: Lord Harries of Pentregarth (Crossbench - Life peer)
Question to the HM Treasury:
To ask Her Majesty’s Government how many Advance Thin Capitalisation Agreements (1) were agreed, and (2) were in force, in (a) 2014–15, and (b) 2015–16.
Answered by Baroness Neville-Rolfe - Shadow Minister (Treasury)
HM Revenue and Customs (HMRC) intends to publish Advanced Thin Capitalisation Agreement statistics in due course as part of a wider publication of data relating to HMRC’s work on collecting tax owed to the UK.
Asked by: Lord Harries of Pentregarth (Crossbench - Life peer)
Question to the HM Treasury:
To ask Her Majesty’s Government whether they have discontinued the publication of annual Transfer Pricing statistics; and if so, why.
Answered by Baroness Neville-Rolfe - Shadow Minister (Treasury)
HM Revenue and Customs has not discontinued the publication of these statistics. The Department intends to publish the transfer pricing statistics shortly.
Asked by: Lord Harries of Pentregarth (Crossbench - Life peer)
Question to the HM Treasury:
To ask Her Majesty’s Government what was (1) the weighted average interest rate for intra-group loans under Advance Thin Capitalisation Agreements (ATCAs), and (2) the average level of taxable profits to which ATCA-related tax relief applied, in each year since 2010.
Answered by Baroness Neville-Rolfe - Shadow Minister (Treasury)
HM Revenue and Customs does not hold this information in a form which allows it to be provided without incurring disproportionate cost.
Asked by: Lord Harries of Pentregarth (Crossbench - Life peer)
Question to the HM Treasury:
To ask Her Majesty’s Government what was the total volume of intra-group loans (1) for which Advance Thin Capitalisation Agreements (ATCAs) applied, and (2) in relation to which new ATCAs came into force, in each year since 2010.
Answered by Baroness Neville-Rolfe - Shadow Minister (Treasury)
HM Revenue and Customs does not hold this information in a form which allows it to be provided without incurring disproportionate cost.
Asked by: Lord Harries of Pentregarth (Crossbench - Life peer)
Question to the HM Treasury:
To ask Her Majesty’s Government, further to the answer by Baroness Neville-Rolfe on 18 January (HL Deb, col 212), and in the light of paragraph 17(7) of Schedule 19 to the Finance Act 2016 which provides for the Treasury to make regulations requiring group tax strategies to include a country-by-country report, what steps they are taking to ensure that transnational companies are fully transparent about the real centres of their economic activity and reveal any misalignment between that and where such companies declare their profits for tax purposes in their annual accounts.
Answered by Baroness Neville-Rolfe - Shadow Minister (Treasury)
The Government believes that profits should be taxed where economic activities are performed. The UK has introduced the OECD model of country-by-country reporting. This will provide a clear overall picture of the global position on profit and tax of multinational groups to tax authorities, enabling them to make more informed assessments of where risks lie.
The Government has set out its objective for a comprehensive and effective model of public country-by-country reporting that is agreed on a multilateral basis, to improve transparency over businesses’ tax affairs and build public trust in the tax system. The UK will continue to work with international partners with a view to delivering on that objective. This includes our continued participation in the discussions on the European Commission’s proposal.
Asked by: Lord Harries of Pentregarth (Crossbench - Life peer)
Question to the HM Treasury:
To ask Her Majesty’s Government, in the light of the appeal in Luxembourg of Antoine Deltour against his conviction in June for theft, what steps they are taking to protect whistleblowers who expose companies’ aggressive tax avoidance schemes when those schemes are organised in conjunction with the governments of other EU member states.
Answered by Lord Young of Cookham
The Public Interest Disclosure Act 1998 ensures that workers who raise concerns of wrongdoing to their employer or a relevant external body (by making what is known as a ‘protected disclosure’) and suffer detriment as a result may seek redress through an Employment Tribunal.
With regards to information on tax avoidance and evasion HM Revenue and Customs (HMRC) gathers information from a number of sources including whistle-blowers. Any information which is provided to HMRC is treated as confidential and details of the individual providing the information will not be divulged, without consent, except where compelled by law.
HMRC does not offer immunity from prosecution within the UK or in a third country where that country’s legislation is at odds with UK Legislation.