Finance Bill (Second sitting)

Blake Stephenson Excerpts

Committee stage
Tuesday 28th January 2025 Public Bill Committees

[Blake Stephenson (Mid Bedfordshire) (Con)]

I think Opposition Members are somewhat confused. The Chancellor committed to bringing an amendment forward. I know that the Minister says it will be tabled at a later stage, but why is it so complex that it cannot be considered today, so that it can be scrutinised by the Opposition?

[James Murray]

At the risk of repeating myself, amendments are routinely brought forward in Committee and on Report, and they are scrutinised at both stages of the Bill. The intention is to make sure that the legislation is in the best possible place by the time it gets to Third Reading and receives Royal Assent.

The focus for us is to make sure that this legislation works as well as possible. We are pragmatic about that; we want to make sure that it functions effectively. That is why we are making technical changes by way of Government amendments today, and why there will be further amendments on Report to make the system simpler and more generous, in the way that the Chancellor has set out.

This is about achieving a system that makes the tax system both fairer, in the ways that we have set out, and as simple and attractive as possible for people who want to come to the UK and bring their money to the UK, to invest and spend it here, which will help us to grow the economy.

Question put and agreed to.

Clause 40 accordingly ordered to stand part of the Bill.

Schedule 9

Income Tax and Capital Gains Tax: Remittance Basis and Domicile

Amendments made: 55, in schedule 9, page 208, line 24, leave out “sections 56(5)(a), 61G(5)(a) and 61R(5)(a)” and insert “sections 56, 61G and 61R”

This amendment together with Amendment 56 omits subsections that have become redundant in light of the ending of the relevance of domicile to income tax.

Amendment 56, in schedule 9, page 208, line 25, leave out from “payment)” to end of line 27 and insert “, omit subsections (4) and (5).”

This amendment together with Amendment 55 omits subsections that have become redundant in light of the ending of the relevance of domicile to income tax.

Amendment 57, in schedule 9, page 210, line 34, at end insert—

“Premium trust funds

21A In section 174 of FA 1993 (premium trust funds), omit subsection (6)(a).

FOTRA securities

21B (1) In section 22 of F(No.2)A 1931 (Treasury power to issue securities with a FOTRA condition)—

(a) in subsection (1)(b), for “persons who are neither domiciled nor resident in the United Kingdom” substitute “exempt persons”;

(b) after subsection (1) insert—

“(1A) For the purposes of subsection (1), the following persons are “exempt persons”—

(a) individuals who are not resident in the United Kingdom, and

(b) persons who are not individuals and are neither domiciled nor resident in the United Kingdom.”

(2) In section 154 of FA 1996 (FOTRA securities), in subsection (1)—

(a) after “applies,” insert “where the person with the beneficial ownership of the securities is not an individual and”;

(b) for “the person with beneficial ownership of the securities” substitute “that person”.

(3) Any security issued before 29th April 1996 with a FOTRA condition shall be treated in relation to times on or after 6 April 2025 as if—

(a) it were a security issued with the post-1996 FOTRA conditions (and with no other FOTRA condition), and

(b) the post-1996 FOTRA conditions had been authorised in relation to the issue of that security by virtue of section 22 of F(No.2)A 1931.

(4) In sub-paragraph (3) —

“a FOTRA condition” means a condition about exemption from taxation authorised by section 22 of F(No.2)A 1931;

“the post-1996 FOTRA conditions” means the conditions about exemption from taxation with which 7.25% Treasury Stock 2007 was first issued by virtue of section 22 of F(No.2)A 1931.”

Amendment 58, in schedule 9, page 210, line 34, at end insert—

“Reliefs in respect of income from investments etc. of certain pension schemes

21C In section 614 of the Income and Corporation Taxes Act 1988 (exemptions and reliefs in respect of income from investments etc. of certain pension schemes), in subsections (4) and (5), omit “not domiciled and”.”—(James Murray.)

This amendment removes references to domicile in provisions of the Income and Corporation Taxes Act 1988 relating to relief on income from investments of certain pension schemes.

Schedule 9, as amended, agreed to.

Clause 41 ordered to stand part of the Bill.

Schedule 10

Temporary repatriation facility

Amendment made: 59, in schedule 10, page 214, line 6, leave out paragraph (a) and insert—

“(a) Part 2 of this Schedule (exemptions etc for designated qualifying overseas capital),”—(James Murray.)

This amendment corrects an incorrect reference.

Schedule 10, as amended, agreed to.

Clause 42 ordered to stand part of the Bill.

Schedule 11 agreed to.

Clause 43

Trusts: connected amendments, transitional provision etc

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