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Dawn Primarolo: I shall respond briefly to the comments of the hon. Member for Chichester. He summed up precisely the position of dividends, interest and royalties in articles 10, 11 and 12 and went on to ask me about the stock exchange capitalisation. I do not have that information to hand, but my officials will do their best to enable me to provide it. The hon. Gentleman is right to point out that it relates to what is to happen, particularly with regard to investment by BP. I do have some figures that might interest him: the Caucasus pipeline project started in 2004. The two projects on that pipeline are worth around $8 billion—we are talking about huge investments—and we are aware of two other large British investors, one with investments of about $60 million and the other with some $90 million-worth. The hon. Gentleman was right to speak about the importance for the future of the double taxation treaty. It is early days, but it is none the less important to have it in place.
The hon. Gentleman spoke also of the rapid changes in Georgia and its emerging democracy. Although we had a double taxation treaty with the Soviet Union, from 1991 onwards Georgia did not recognise such treaties. Therefore, it is important to implement this treaty.
To turn to the points that the hon. Member for Torridge and West Devon (Mr. Burnett) raised, first, the £2 million figure is per annum, on qualifying investments, not an overall limit. Secondly, he asked about wealth tax in Georgia, but then answered his own question: we would not give double taxation relief on a tax that we do not charge in the first place. Members of the Committee may have a view on that.
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The hon. Gentleman mentioned the exchange of information, which we have discussed a number of times in Committee. There has been a change of wording, and until recently the recommended OECD model used the word ''necessary'' in the draft articles on exchange of information. That was updated to the phrase ''foreseeably relevant''. We had quite a long discussion about that when we discussed the New Zealand arrangements. Georgia started its negotiations with us on the old double taxation OECD model, with the word ''necessary'', and was not of a mind to change that to ''foreseeable'' or ''relevant''. Basically, we operated in the same way and the change does not really make a great deal of difference. [Interruption.] The hon. Gentleman does not need to keep pointing at me; I know the answers to his questions.
The hon. Gentleman raised the issue of confidentiality. Again, the rules are strict. Any release of information from the Inland Revenue to anybody, let alone another tax authority, must be done on the provision of specific information, and on the basis of a specific allegation and the demonstration of good reason to suspect money laundering, fraud or whatever.
The hon. Gentleman asked about the Serious Organised Crime and Police Bill, which will be read a Second time tomorrow. If he wants to know about the powers of the proposed agency, Second Reading of the Bill might be a more relevant occasion to find out. The terms under which information will be released from the Inland Revenue to any organisation remain, exactly as I have repeatedly explained to this Committee and others, and for the protection of taxpayers' information.
The hon. Gentleman's last question was when we expected the Georgian Parliament to ratify the treaty. We expect that by the end of the year, so that the treaty can be in operation for the start of the next financial year.
In conclusion, the £2 million is per annum, we do not have a wealth tax and therefore cannot give relief on it, the exchange of information relates to the OECD change, the hon. Gentleman can raise issues to do with the serious organised crime agency tomorrow, and we hope that the treaty will be ready for the beginning of the financial year.
Mr. Burnett: I have a funny feeling that the £2 million might be a one-off arrangement, not per annum. Can the Paymaster General confirm that?
Dawn Primarolo: Yes. I thank the hon. Gentleman for that correction, although I wonder why he asked a question to which he already knew the answer. I said twice that the £2 million was per annum, which was incorrect, so I am grateful for his correction.
Question put and agreed to.
Resolved,
That the Committee has considered the draft Double Taxation Relief (Taxes on Income) (Georgia) Order 2004.
Committee rose at six minutes to Five o'clock.
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