Draft Double Taxation Relief and International Tax Enforcement (Taiwan) Order 2021

James Murray Excerpts

Thursday 25th November 2021 General Committees

[James Murray (Ealing North) (Lab/Co-op)]

Thank you for the opportunity to respond on behalf of the Opposition, Ms Rees, as we consider this order on double taxation relief and international tax enforcement with the territory of Taiwan. It is a pleasure to serve under your chairmanship again.

The schedule to the order contains a protocol that amends an agreement in relation to the territory of Taiwan dealing with the elimination of double taxation with respect to capital gains tax, corporation tax and income tax, the prevention of tax avoidance and evasion and international tax enforcement. The agreement aims to eliminate the double taxation of income gains arising in one territory and paid to residents of another territory. As we have heard, that is done by allocating the taxing rights that each territory has under its domestic law over the same income and gains, and by providing relief from double taxation. There are also specific measures combating discriminatory tax treatment and providing for assistance in international tax enforcement.

As we can see, the amendments to the agreement are relatively minor and technical in nature, mostly updating terminology to bring about consistency with similar bilateral agreements with other states and territories. Various articles within the schedule replace outdated terminology, and further technical amendments are added to the schedule, relating to persons covered, taxes covered, general definitions, residents, dividends, interest, royalties, capital gains, limitation of relief, non-discrimination, mutual agreement procedure and exchange of information. An article relating to entitlement of benefits is also added to the agreement.

The Opposition will not oppose this order. It is, of course, important that bilateral agreements concerning taxation are clear and up to date, and that revenue generated from taxation is neither inappropriately drawn nor inappropriately allocated. Similarly, we support the measure to reduce the administrative burden on Her Majesty’s Revenue and Customs, which would otherwise have to process rebate applications.

While we are on the matter of international taxation, however, I would like to briefly ask the Minister, as this is the first time we have had the chance to discuss the matter, her view on the global minimum corporation tax rate that the OECD and G20 recently agreed. In her response, I would be grateful if the Minister could confirm whether 15% is the rate the Government had hoped for, or whether they had hoped it might be higher or lower.

[The Chair]

I am not sure that question is quite in scope, but it is at the Minister’s discretion whether she responds to it.