Into heavy weather

KEY POINTS

• Loan relationship rules to be made EU compliant.
• A new definition of an ‘offshore fund’.
• Principles-based legislation for disguised interest.
• Amendments to remittance basis and non-domicile rules.

The ninth sitting of the Public Bill Committee’s review of the Finance Bill 2009 started with a debate on Schedule 19: ‘Income tax credits for foreign distributions’.

Ian Pearson Economic Secretary to the Treasury introduced a minor tidying-up amendment which ‘sailed through’ before the debate moved to an Opposition amendment which Mark Hoban felt would run into heavier water.

He explained that since 6 April 2008 individual shareholders with holdings of less than 10% in non-UK-resident companies have been entitled to a non-payable dividend tax credit but this did not apply to dividends from offshore funds to counter the inequality of treatment of...