Edmonds BarbaraBARBARA EDMONDS (Labour—Mana): Fa'afetai tele lava Madam Speaker. I move to take a call on the Taxation (Annual Rates for 2020-21 Feasibility Expenditure and Remedial Matters) Bill. First of all as part of my contribution I'd like to thank the independent adviser Therese Turner for her sound and practical advice. Where there are 20-something officials working on a bill there is only one Therese. So I am thankful for her diligence and no doubt the late nights she spent on this bill. But I do also want to acknowledge the 20-something officials who did work on this bill. Having come from a tax policy background I understand they've got to do Cabinet papers they've got to do commentary on the bills they've got to do officials' report they've got to service the select committee at every point that we need advice. So I totally absolutely support officials and I thank them for their responsiveness and the advice given on this bill.To our submitters thank you. To the many tax practitioners who have submitted on this bill most of them would have submitted on this bill not because they were being billed to do so but because they understand the integrity the cohesiveness and the efficiency of the tax system means that they want to submit on this bill so that the tax system works practically. Again I thank you so much for your time.Specifically to the bill one thing the Minister of Revenue said throughout his speech was integrity". It's a really key word in our tax system and what he said was even though we're in COVID times we need to ensure the integrity of the tax system closes the gaps. And that's why we continually review tax legislation. That's why you normally would have two to three omnibus tax bills throughout a year because as issues arise you fix them. The purchase price allocation amendments speak to integrity; the amendments to subpart CB of the Income Tax Act or the land rules speak to the integrity of the system. Even the most taxpayer-friendly measure in this bill which is the feasibility expenditure rules has moments of integrity in it.Now speaking specifically to the feasibility expenditure rules the genesis of these amendments is in the Supreme Court 2016 TrustPower case. The case limited the deductibility of costs incurred to evaluate the feasibility of a project. So under the normal tax rules if you're incurring revenue you get an expense deduction. If you have a capital asset you get a depreciation deduction. But actually if you're spending money such as on resource consents to see whether actually a wind farm would be good or not you don't get those costs deducted. And so that's what this bill speaks to. That's why since 2016 tax practitioners have been calling on Governments to bring these measures in. So I'm really proud that our Government as part of our whole COVID response and to help increase productivity and innovation is bringing in these rules.The bill in relation to feasibility expenditure has a really key integrity measure and that's called the clawback. So I'm going to focus this next part of my contribution on that integrity measure. So our Finance and Expenditure Committee suggested that based on the advice from Therese Turner one of the points that was raised during the submissions was that the wording of the deduction provision appears to allow deduction for indirect costs. Therese suggested to the committee "I agree with officials that not clawing back all of the expenditure would provide an incentive for businesses to temporarily abandon projects and thereby enable them to claim a deduction that will in part not be reversed when the project is re-started." So she agreed with officials and her recommendation to the committee—which therefore we have approved and we are recommending to the House—is that we have that clawback provision.Another really key change that was made by the select committee in relation to this integrity measure of a clawback provision is to limit that time to around seven years that clawback deduction. The reason why we chose seven years is because currently in the tax legislation and the Tax Administration Act there is a seven-year period for holding your records. The committee believe that it was reasonable to make sure that those rules align with the seven-year clawback. So I stand proud here to be able to be part of a Government that has brought through those feasibility expenditure rules rules that have been called for since 2016. So I commend this bill to the House."