Taxation (International and Other Provisions) Bill

My Lords, I beg to move that this Bill be read a second time, and indicate the pleasure with which I undertake this obligation. The Bill rewrites a number of international provisions, such as the double taxation relief and transfer pricing provisions. In order to help users, it also relocates and, where appropriate, rewrites provisions which would otherwise have been left unhelpfully in the Income and Corporation Taxes Act or one of the Finance Acts. Its main aim is to make the legislation clearer, better structured and easier to use than the source legislation, which is often dense and difficult to follow. The Bill has been produced by Her Majesty’s Revenue and Customs Tax Law Rewrite Project. It is the final Bill of the project, and follows the success of the project’s previous Acts which we have all enjoyed debating in the House on previous occasions, and which rewrote the capital allowances and income tax legislation and the first instalment of the corporation tax provisions. The second and final instalment is included in another Bill which will be with us shortly. The Bill has not been certified as a money Bill. It was introduced in Parliament in another place in mid-November last year, and, under the special procedures applying to tax law rewrite Bills, the substantive debate on Second Reading was held in Committee. The Bill then passed to a Joint Committee of the two Houses where it was considered on 11 January. The Joint Committee included among its members the noble Lords, Lord Blackwell and Lord Goodhart, the noble Baroness, Lady Goudie, and the noble Lord, Lord Newton, who I am pleased to see in his place. I pay particular tribute to the work he has done repeatedly with regard to this very significant project, and I have no doubt that he is more relieved than any other noble Lord that we are coming to a conclusion. I also appreciate the work of the noble Baroness’s colleague in another place, Andrew Tyrie, who chaired the committee and did sterling work. The Bill then passed back to the House of Commons to be debated at Third Reading and is now before us for its remaining stages. Unlike previous rewrite Bills, this Bill is not a money Bill. Accordingly, if given a Second Reading today, it will be committed to a Committee of this House—although I very much hope that noble Lords will take the view that this Bill ought not to be amended, and I hope the noble Lord, Lord Newton, is here to give his benign support to that proposition. It is beyond the remit of the project to make any significant changes in tax policy, and so it takes great care to preserve the effect of the legislation. It can, however, make very minor agreed changes—for example, to remove ambiguity, repeal obsolete material or correct minor anomalies. To ensure that any changes made are within the remit of the project, they are considered during an extensive, detailed and thorough consultation process involving the project’s consultative committee whose members are drawn from the main tax professional and business representative bodies. We have been grateful to them in the past, too, for the work that they have done. Overall, the work is overseen by the independent steering committee, chaired by the noble Lord, Lord Newton. The extensive consultation process that I mentioned involved publication, for public comment, of papers containing almost all the clauses in the Bill, and the Bill was also published in draft form for another round of consultation. An updated version was later published taking account of the consultation responses and the changes made by the Finance Act 2009. Throughout the process, proposed minor changes in the law were specifically drawn to the attention of consultees, and no minor changes in the law were included in this Bill without the considered approval of both the project’s committees. The Joint Committee of both Houses heard oral evidence from members of the Tax Law Rewrite Project team. It considered and accepted all the government amendments to the Bill, all of which it agreed were of a minor, technical nature, as was entirely appropriate. The Joint Committee concluded that the Bill is a welcome clarification of the existing law and, as a result, it will be easier to use and more accessible to Parliament, the judiciary, informed professionals, business people and other users of the legislation. It was satisfied that the changes to the law in the Bill are of very minor significance, as I mentioned earlier. The success of the project in improving the accessibility of tax legislation to users has been borne out by independent market research, which has shown that in the main users of rewritten legislation have warmly welcomed it. It was seen to be of particular help to those newly entering the profession. Consultees have also been positive about the project’s work. It would be wrong of me to conclude without paying tribute to everyone who has taken part in this work. I sum up by saying that they have been responsible for an extremely worthwhile project with a track record that shows that it makes our direct tax legislation more modern, clearer and easier to use. The Bill maintains the high standards achieved in the project’s previous Acts and will make the legislation more accessible to all. Accordingly, I commend the measure to the House.