Draft Double Taxation Relief and International Tax Enforcement (Peru) Order 2025 Draft Double Taxation Relief and International Tax Enforcement (Romania) Order 2025 Draft Double Taxation Relief and International Tax Enforcement (Andorra) Order 2025 Draft Double Taxation Relief and International Tax Enforcement (Portuguese Republic)) Order 2025

Dan Tomlinson Excerpts

Monday 1st December 2025 General Committees

[The Exchequer Secretary to the Treasury (Dan Tomlinson)]

I beg to move,

That the Committee has considered the draft Double Taxation Relief and International Tax Enforcement (Peru) Order 2025.

[The Chair]

With this it will be convenient to consider the draft Double Taxation Relief and International Tax Enforcement (Romania) Order 2025, the draft Double Taxation Relief and International Tax Enforcement (Andorra) Order 2025 and the draft Double Taxation Relief and International Tax Enforcement (Portuguese Republic) Order 2025.

[Dan Tomlinson]

It is a pleasure to serve on this Committee with you as Chair, Mr Swayne.

The orders before the Committee give effect to the double taxation conventions, or DTCs, with Andorra, Peru, Portugal and Romania. Like all DTCs, these agreements will provide tax certainty to businesses and investors by removing double taxation and, importantly, without creating opportunities for the avoidance of tax. In doing so, they will remove barriers to cross-border trade and investment, support growth, and provide a clear and fair framework for taxing businesses that invest and trade across borders. That will benefit businesses and the economies of both the UK and our respective treaty partners.

The DTCs are based mainly on the OECD model tax convention, which contains a set of internationally agreed principles and standards that make them easier for businesses to understand and tax administrations to apply. Those standards ensure that DTCs are not used to avoid or evade tax. They include a statement to that effect in the preamble, and are clear that it is not a purpose of a DTC to create opportunities for tax evasion and avoidance.

The DTCs include a principal purpose test that denies treaty benefits in case of abuse. They also allow for the exchange of information between the UK and its treaty partners to facilitate tax transparency. Other anti-avoidance rules in the new treaties include a tie-breaker provision for determining corporate residence based on agreement between the competent authorities of the treaty partners. The orders include dispute resolution provisions, which provide that where a taxpayer considers that the DTC has not been applied correctly, they can present their case to either tax authority, allowing both countries to work together to resolve the issue.

Together, those features strengthen our collective defences against tax avoidance and evasion while supporting cross-border trade, investment and mutual growth. I commend all the orders to the Committee.

--- Later in debate ---

[Dan Tomlinson]

I—

[Lincoln Jopp (Spelthorne) (Con)]

Will the Minister give way?

[Dan Tomlinson]

I will.

--- Later in debate ---

[The Chair]

None was taken.

[Dan Tomlinson]

I thank the hon. Member for giving me the chance to correct the record that we have a Sir in the Chair today—Sir Desmond Swayne. I am very grateful for your chairmanship, Sir Desmond.

On the impact of these different DTCs, trade with Andorra is only £93 million a year, so the impact will be relatively small for some of these measures. The impact will be larger with both Portugal and Romania as they are already very significant trading partners and we trade a similar amount with both.

On the hon. Gentleman’s second question, Romania has ratified this already and Peru, Andorra and Portugal are expected to do so by the end of the year.

Is this the moment where I conclude, or do I sit down now?

[The Chair]

The choice is yours, Minister.

[Dan Tomlinson]

In closing, Mr Chair—

[Lincoln Jopp]

Sir Chair.

[Dan Tomlinson]

In closing, Sir Chair, the orders before the Committee implement DTCs between the United Kingdom, Andorra, Peru, Portugal and Romania. The conventions will ensure that we have a modern DTC in place with all four of these countries, which will provide a stable foundation for trade and investment to grow, while at the same time making it harder to avoid taxes here in the United Kingdom. I am grateful to all hon. Members—Sirs and non-Sirs—for their contributions to the debate.

Question put and agreed to.

Draft Double Taxation Relief and International Tax Enforcement (Romania) Order 2025

Resolved,

That the Committee has considered the draft Double Taxation Relief and International Tax Enforcement (Romania) Order 2025.—(Dan Tomlinson.) 

Draft Double Taxation Relief and International Tax Enforcement (Andorra) Order 2025

Resolved,

That the Committee has considered the draft Double Taxation Relief and International Tax Enforcement (Andorra) Order 2025.—(Dan Tomlinson.)

Draft Double Taxation Relief and International Tax Enforcement (Portuguese Republic) Order 2025

Resolved,

That the Committee has considered the draft Double Taxation Relief and International Tax Enforcement (Portuguese Republic) Order 2025.—(Dan Tomlinson.)