Question to the HM Treasury:

To ask the Chancellor of the Exchequer, what estimate his Department has made of the level of revenue accrued to the public purse as a result of new sub-section 259HA(5)(b) Chapter 8 Part 6A TIOPA 2010 as outlined in clause 38 of the draft finance bill.

The level of revenue accrued to the public purse as a result of the implementation of sub-section 259HA(5)(b) in Chapter 8 Part 6A TIOPA 2010 as outlined in clause 38 of the draft finance bill is expected to be negligible. Estimates approved by the Office for Budget Responsibility are not available.

More information can be found in the Tax Information and Impact Note published on 8 July 2018:

https://www.gov.uk/government/publications/hybrid-and-other-mismatches-anti-tax-avoidance-directive/hybrid-and-other-mismatches-anti-tax-avoidance-directive