§ Mr. Wrigglesworthasked the Chancellor of the Exchequer if the Government are satisfied with the operation of the Double Taxation Relief (Taxes on Income) (the United States of America) Order 1980 in respect of the impact of unitary tax on British interests.
§ Mr. Ridley[pursuant to his reply, 8 December 1981, c. 383]: Under its original terms article 9(4) of the Double Taxation Convention between the United Kingdom and the United States of America would have prevented individual States from taxing United States subsidiaries of British 511W companies on the unitary basis. In view of the United States Senate's decision to eliminate the application of this article to American State taxation we continue to urge strongly the United States authorities to propose or support legislation that would prevent the application of unitary taxation by individual States.
§ Mr. Gryllsasked the Chancellor of the Exchequer whether he has made representations to the United States' Government orally or by letter, in the last six months, to seek action by the United States' Government to introduce legislation to prohibit States in the United States of America taxing British companies operating in such States by unitary tax on a world-wide reporting basis; and if he will make a statement on representations he has received from British companies on this subject during the last two years.
§ Mr. Ridley[pursuant to his reply, 3 December 1981, c. 188]: The Government have strongly urged the United States Government to introduce or support legislation to prevent the application by States of a unitary basis of taxation to British companies, not least because of the representations received from British industry. Within the last six months fresh approaches have been made, both orally and in writing, to the present Administration, and these include a note presented by the United Kingdom on behalf of the European Community expressing the joint concern of the ten Governments.