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Mr. Hands: A final question: has the Financial Secretary considered giving grandfather rights to those who can currently take advantage of their personal allowances, so that they may continue before they are affected by the measure?
Mr. Timms: As I understand it from legal advice, there would not be a legal basis for taking such action. We are not in a position to discriminate in that way. The clause puts the position right and removes the discrimination.
Question put and agreed to.
Clause 5 accordingly ordered to stand part of the Bill.
Schedule 1 agreed to.

Clause 6

Additional rate, dividend additional rate, trust rates and pension tax rates
The Chairman: It may be more convenient for the Committee to debate clause 6 in tandem with schedule 2. I do not know whether that will create problems. If it is difficult, we shall discuss them separately.
Mr. Hands: Mr. Atkinson, I certainly prefer to discuss schedule 2 separately. I have some technical points to make that are specific to it. If it is possible to have a separate debate, I should be grateful.
The Chairman: In that case, I will accept a wide-ranging debate on clause 6, and we can deal with the more technical matters under schedule 2. I hope that everyone finds that suitable.
Question proposed, That the clause stand part of the Bill.
Mr. Timms: I am happy to take your guidance, Mr. Atkinson, and comment on both the clause and the schedule, but I shall also be happy to have a separate conversation about the schedule when we reach that stage.
Clause 6 introduces schedule 2, which provides for the additional rate of tax from 2010-11. The rate will be set at 50 per cent. in 2010-11 and apply to those with taxable incomes above £150,000 a year. As you will recall, it was announced in the pre-Budget report in November that we would be introducing a 45 per cent. rate in April 2011. However, the global downturn has been worse than predicted and, as a result, more consolidation is required. That is why the additional rate has been brought forward and raised by five percentage points to 50 per cent.
Mr. Mark Field (Cities of London and Westminster) (Con): In view of the Budget’s optimistic projections for growth in the next few years, on what basis did the Treasury feel it necessary to change its proposal for a 45p tax rate? After all, if Government figures are to be believed, we shall have growth racing away at 3.5 per cent. within the next year or so. On the basis of that figure very little obvious change has been made in relation to public expenditure, so why the radical change on taxation?
Mr. Timms: Because, as I said, expectations for the world economy have gone backwards—in an adverse direction—to a significant extent since November of last year. The International Monetary Fund has revised its forecasts two or three times in that period—downwards in all cases—so what we needed to do was what we put in place in the Budget: a trajectory that we could deliver on, getting us back to balance by a later point than we said in November, by 2017 rather 2015. The measure is an important contribution to that.
Several hon. Members rose
Mr. Timms: I have a rich choice of interventions to select from—I shall take the hon. Member for Cities of London and Westminster first.
Mr. Field: A choice made only in ascending order, obviously, which I fully understand.
Those concerns have been expressed to me. Do we have an assurance from the Financial Secretary that there will be no further downward projections regarding the world economy? Is the matter now set in stone? The position has deteriorated appallingly since last November—or so he would tell us. Is he now entirely clear that the figures are final, and we shall have no further downward projections in the months and years to come?
Mr. Timms: All I can say to the hon. Gentleman is that the projection at the time of the Budget was the best available, given the data at that point. I wish I could tell the Committee with absolute confidence what will be happening in the next one, two or three years, but in reality we are not in that happy position.
Mr. Peter Bone (Wellingborough) (Con): The logic of the Financial Secretary’s argument is that he cannot confirm the figure for the top rate. If the growth forecasts are worse than predicted, the logic is that he will come back and say, “Well, it is 60 or 70 per cent.” Perhaps we shall go back to the days of 98 per cent., or even the negative of 101 per cent., which we had under a Labour Government.
Mr. Timms: The question before the Committee is whether it is right to raise the level to 50 per cent., as in the clause and schedule. My case to the Committee is that it most certainly is right. I am conscious that, and pleased that, the hon. Gentleman’s party has not dissented from that view, and I want to set out the basis for that being the right decision.
Mr. Hands: The Financial Secretary is being most generous in giving way. One of the most important things is surely the stability and predictability of the UK tax system. In that regard, what kind of message does he think it shows that the 45p tax rate has been abolished before it has even been introduced?
Mr. Timms: The hon. Gentleman will, I think, have noticed that there has been unprecedented turbulence in the world economy over the past few months. I hope that that has not passed him by. Policy needs to change in the light of circumstances. We have moved swiftly and boldly—that is absolutely the right thing to do—to maintain the stability of the British economy and to put the public finances on the right trajectory for balance.
John Howell (Henley) (Con): The point that many of us are struggling to understand here—we all understand that the global economic situation, and particularly the situation in the UK, worsened between the pre-Budget report and the Budget—is that there is a world of difference between those sweeping, global pictures that the Financial Secretary has painted and the specifics of the difference between the pre-Budget report and the Budget. What we would like to understand is how he has got from one to the other.
Mr. Timms: That is the very stuff of politics—to take the grand sweep, to see what is going on in the world and to decide what one will do in response. I shall set out the basis of what I want to put to the Committee. As I said, I am pleased that the Conservative party has not dissented from the view that this is an important measure, contributing to the consolidation that is now required. We have certainly looked carefully at the likely impact, on both individuals and the economy, as a consequence of the 50 per cent. rate.
Stewart Hosie (Dundee, East) (SNP): The Financial Secretary is talking about the competitive tax rate. May I bring him back to the clause for a moment? Subsection (4)(b) states: “‘for 32.5% substitute 42.5%’”. If I have read the Red Book correctly, table A3, annotation 2, states:
“The rates applicable to dividends are 10 per cent for dividend income up to the basic rate limit and 32.5 per cent above that.”
As I understand it, that figure is now going from 32.5 to 42.5 per cent.—a rise of more than 30 per cent. Does the Financial Secretary think it right that basic rate taxpayers who have dividend income above the basic rate threshold should be—if I have understood this correctly—subject to an increase from 32.5 to 42.5 per cent.?
Mr. Timms: I shall come to the implications for some of the other rates in a moment. The point I am making is about the 50 per cent. rate on income above £150,000, but there are some knock-on consequences, which I will spell out in a moment.
In answer to the hon. Gentleman’s question, yes, this measure is consistent with the competitiveness of the UK as a place for investment in business, consistent with fairness, and consistent with the consolidation that is needed over the next few years. The measure will raise more than £6 billion in its first three years. That estimate takes into account, as all our estimates do, behavioural consequences of the change, about which we had some discussion this morning. As I also mentioned this morning, the assumptions that underpin our view of the yield coming from this measure were confirmed by the Institute for Fiscal Studies in its post-Budget briefing as “not unreasonable”.
Some have suggested that the behaviour impacts are such that we should not make that change. I do not agree with that, because without this measure, focused on those with the very highest incomes, funding would need to be found elsewhere. Our choice has been to look, in this clause, to those who are in the best position, who are most able to afford to pay, and whose incomes have risen a good deal faster than the average over the last decade.
Mr. Brian Binley (Northampton, South) (Con): I am a little surprised that the Financial Secretary mentioned the Institute for Fiscal Studies, because it also predicted that the tax would generate almost nothing. I am wondering whether the definition of “almost nothing” and agreement with the Financial Secretary coincide. This causes me concern, and I am also concerned that the Chancellor said that there was no science to choosing the 50 per cent. tax rate. I want to be absolutely sure that this is a revenue-raising measure. Will the Financial Secretary give me a total assurance that that is the case and that it will not in fact diminish revenues, which is a possibility?
5 pm
Mr. Timms: I simply refer the hon. Gentleman to the post-Budget presentation by the IFS, which I have in front of me. The IFS says on one of its slides:
“How much will the 50% rate raise? HM Treasury says £2.4 bn.”
A little further down, it says:
“Government’s assumptions not unreasonable.”
That was my point, and it is certainly my view that the measure will raise a substantial amount for the Exchequer and make an important contribution to the consolidation that is required.
Let me move on to the question put by the hon. Member for Dundee, East about some of the consequences or knock-on effects of the change. The rate of tax due on dividends over the same income threshold is raised, as he said, to 42.5 per cent. The clause also raises the trust rate to 50 per cent. and the dividend trust rate to 42.5 per cent., to ensure that there is no incentive for somebody to put money into a trust simply to reduce tax liability.
On dividend income, let me be clear: dividend income over £150,000 will be subject to the 42.5 per cent. rate; a rate of 32.5 per cent. will continue to apply up to that amount. In other words, basic rate taxpayers, about whom the hon. Gentleman is particularly concerned, in receipt of dividends will not be affected.
Another consequence of the 50 per cent. tax rate is the impact on special rates of tax in the pensions tax rules. Those rules operate on the basis that individuals receive tax relief at their top tax rate on pension savings up to prescribed limits. If those saving limits are exceeded, tax charges are applied to recover tax relief on contributions. The clause puts in place powers to vary the rates for those special pensions tax charges in regulations, a point that is mentioned in the letter that has been circulated this afternoon.
We have thought very carefully about how the further money required for fiscal consolidation should be raised. We are clear that it is right to require those who benefited most in the last decade and who are in the best position to pay to contribute more. That is the basis for the clause. I will now give way to the hon. Gentleman.
Mr. Hands: The Financial Secretary really is being very generous in giving way. Can he just tell us how he thinks he will present to the electors of East Ham at some point within the next 13 months the fact that he has broken his own general election manifesto pledge from 2005? Perhaps he thinks otherwise, but the manifesto said clearly:
“We will not raise the basic or top rates of income tax in the next Parliament.”
Mr. Timms: The measure is rather popular among my constituents in East Ham. They look to the Government to take the right decisions for the future of our country. In extraordinary circumstances, of the sort that we have seen in the world economy in the past few months, it is right of the Government to put in place the measures that are needed to safeguard the economy, families and businesses, and to secure the consolidation that will be needed in the next few years. The measure is an important step towards doing that.
Mr. Hands: I thank the right hon. Gentleman for that response. I think that he is saying that the measure will be popular in East Ham and that he will campaign on that basis. Is he also saying that he will campaign nationwide on the basis that the measure will be popular?
Mr. Timms: I believe that it is a popular measure nationwide.
Mr. Hands: We have got to the heart of the matter. I am now going to talk at some length about the 50p tax rate and ancillary matters. I hope to cover quite a wide range of topics, including, first, the reactions to the proposed 50p rate and, secondly, a question that we have not really covered yet, which is whether the proposed 50p rate will be a temporary measure or permanent. Thirdly, I will examine whether the measure will raise the amount that it is claimed it will raise, and whether it might not be beyond the point of revenue maximisation. Fourthly, I will look at the UK’s overall economic competitiveness. Fifthly, I will look at the political background and reasons for introducing the 50p tax rate and some of the other measures. I will also look at the complexity that the abolition of the 45p tax rate—before it was even introduced—will add to the unpredictability of the UK tax code. Furthermore, I will discuss some of the more technical provisions relating to trust dividends and pensions before drawing some conclusions.
This is the first rise in the top rate of tax since 1974, after 35 years of it either being stable or reduced. It is worth reiterating that the Government estimate that the new 50p rate on earnings above £150,000 will raise £1.13 billion in 2010-11, rising to £2.52 billion in 2011-12. However, the new tax rate’s implementation is largely the result of political posturing. The change sends the wrong signal to entrepreneurs who are in the UK and to those who might be attracted to come here, and it will lead many to question the UK’s economic competitiveness, especially in relation to its tax code. The proposal also adds to massive uncertainty about the UK tax system and is a reminder of the importance of predictability in that system. Moreover, it adds significantly to UK tax complexity, which, as we heard this morning, is already a developing theme in our deliberations on the Bill. The 11 different marginal tax rates that have been created in recent years are incredibly complex.
Questions remain about whether the proposal will raise anything like the amount that has been suggested, and I am disturbed by the earlier evidence that, in the Treasury’s assessment of what the measures will yield, it did not separate the phasing out of allowances on the one hand, and the introduction of the 50p tax rate on the other. There seems to be an assumption that those two factors will prompt the same behavioural reaction, but people’s reactions may well be very different. For example, somebody who currently earns £95,000 but may expect to earn £105,000 might go about not earning that extra £10,000, but doing something else; on the other hand, somebody who earns £250,000 might decide to relocate. It is fundamentally flawed to throw two kinds of consideration into the same estimate of revenue.
The ancillary changes to pension and dividend rates act as a severe disincentive to save and they send the wrong message on saving—my hon. Friend the Member for South-West Hertfordshire spoke earlier about the importance of our savings culture. Also, the change to the trust rates might have a perverse impact on many who are not well off and are about to suffer undue hardship as a result of the Government’s measures.
Reactions to the 50p tax rate announcement were very interesting. We will turn to focus groups in due course.
Mr. Jeremy Browne (Taunton) (LD): From the tenor of the hon. Gentleman’s introductory remarks, one could be forgiven for thinking that he is opposed to the 50p tax rate.
 
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