Unitary Taxation (Hansard, 16 January 1984)

§ Mr. Moore

[pursuant to his reply, 19 December 1983, c.20]: Since 1979 the Government have taken every opportunity to impress on the United States Administration and United States opinion generally, their opposition to the application of unitary taxation to United Kingdom-based companies. We have, like other Governments and representatives of United Kingdom business, emphasised the importance of the United States Administration achieving a satisfactory resolution of this issue. The Government's representations to the United States Administration are too numerous to list individually. They include letters, ministerial discussions and formal notes by the United Kingdom Government and by the European Community. The Prime Minister has discussed the matter personally with President Reagan. The Government have delivered a note of their views to the United States Treasury working party considering the issue under the chairmanship of Treasury Secretary Regan. So has the European Community. Notes have also been delivered by 26W a number of other Governments, and by international business interests — including the Confederation of British Industry and the Unitary Tax Campaign. The Government await with interest the proposals of the United States Administration to their international trading partners following the Working Group's report.

The representations made by the United Kingdom Government, individually and as part of the European Community, include:

March 1980— The Government and other member states of the European Community presented a note to United States State Department urging action on unitary taxation. The United Kingdom independently delivered a note to State Department.
October 1981 —The United Kingdom—as President of the Community — delivered a note on behalf of the European Community.
December 1981 — The Chancellor of the Exhcequer wrote to Treasury Secretary Regan successfully urging the United States Administration to file an amicus curiae brief in the case of Chicago 52c Bridge and Iron Company v. Catepillar Co et al before the Supreme Court.
June 1982 — Joint note with European Community urging the United States Administration — unsuccessfully — to file a further amicus curiae brief in the Supreme Court Case of Container Corporation of America Ltd v. Franchise Tax Board.
July 1983 — Letter from Chancellor of the Exchequer to Secretary Regan urging legislation following Supreme Court decision in "Container".
1 August 1983 — Further European Community note to the State Department.
30 August and 16 September 1983 — Letters from Prime Minister to President Reagan. These were followed by discussions in Washington between the Prime Minister and President Reagan, and separate meetings of the Prime Minister and Chancellor with Secretary Regan.
10 November 1983 — European Community submitted brief of amicus curiae for hearing of the case of Shell Petroleum Nv v. California Franchise Tax Board before the Supreme Court.
21 November 1983 — United Kingdom Government submitted brief of amicus curiae for hearing of Alcan Aluminium Ltd v. California Franchise Tax Board before the Supreme Court.
30 November 1983 — United Kingdom Government note to working group on unitary taxation. EEC note to the working group.

The most recent discussions of the matter with the United States Administration were on 8 December 1983, when it was raised by the Prime Minister and the Chancellor of the Exchequer at meetings with Secretary Regan in London.