Meeting of minds

The eighth and ninth sittings of the Finance Bill are reported by ALLISON PLAGER.

ANTI AVOIDANCE LEGISLATION opened the eighth sitting of the Public Bill Committee's debate on the Finance Bill. Theresa Villiers asked for clarification of aspects of clause 34 'Schemes etc. designed to increase double taxation relief'. Stephen Timms (then) Chief Secretary to the Treasury confirmed that the clause introduced changes to TA 1988 s 804ZA brought in by the FA 2005 aimed at schemes and arrangements designed to increase double tax relief. He said that it was intended to 'put beyond doubt' what was foreign tax for the purpose of the legislation rather than instigate change. This was necessary because of recent disclosures of schemes purporting to avoid the effects of the 2005 Act on the basis that the tax in respect of which double tax relief is claimed is UK tax rather...