Cross-border Trade and Accounting

Lord Mackinlay of Richborough Excerpts

Wednesday 30th October 2019 Commons Chamber

[Craig Mackinlay (South Thanet) (Con)]

I congratulate my hon. Friend the Member for Ochil and South Perthshire (Luke Graham) on securing the debate. We came to a bit of a joint decision that it should happen around the time of the withdrawal agreement, because much of the debate on that has been about how borders will operate post Brexit. The hon. Member for Strangford (Jim Shannon) obviously has concerns, as do I, about the differences between trade happening between GB and NI, between NI and GB, and across the Republic border. I think we all want those things to be as seamless as possible.

As my hon. Friend the Member for Ochil and South Perthshire said, we are not in the old world of wet stamps and guys with kepi caps on borders checking paperwork; we are very much in a new world where digital information is in place to make things work. I have had concerns—I refer to my entry in the Register of Members’ Financial Interests—about the push towards making tax digital, particularly for smaller traders, for which I can see very little use for it. However, bigger companies have naturally migrated away from the old systems of Kalamazoo and paper-based things of years of old—you have to be a very old accountant to remember those—to entirely digital systems. VAT returns now have to be sent completely digitally, with details of all the transactions underlying them.

Therein lies the solution to many of the problems raised. My hon. Friend the Member for Ochil and South Perthshire mentioned the VIES system, which is already live in Northern Ireland. There is also the CHIEF—customs handling of import and export freight—system and economic operators registration. We are in a new world, but for people to say that intra-EU trade is somehow seamless and completely frictionless is simply not true.

[Stephen Kerr (Stirling) (Con)]

What does my hon. Friend say to people like me who are gravely concerned about the degree of complexity in these accounting systems, which makes any kind of audit trail really difficult? The big four audit companies have such a poor record in auditing these accounting systems. What does he say to people like me who are sceptical about how to drive transparency, which was mentioned by my hon. Friend the Member for Ochil and South Perthshire?

[Craig Mackinlay]

I would go against that. I think my hon. Friend will find that the digital trail is more likely to be there than the old paper trail. It is rather like my hon. Friend’s tweet from 10 years ago: it is still there, and it will be with him for a lifetime. This gives us an opportunity to have greater audit accountability. I take his point about the big four auditors, but we are talking about volumes of transactions that are mind-blowing, and to ask an auditor—I declare an interest: I am an auditor, and I still hold registration—to be responsible for every jot of every transaction lacks an understanding of what the audit process is all about.

I will return to the point I was making, because I know that the Minister will want to speak for some time. I was talking about the fact that things are not completely frictionless today. If I sell, as a VAT-registered entity in the UK, to another VAT-registered entity, it is not frictionless. That transaction has to be recorded on both sides, and it will find its way through Making Tax Digital on to a VAT return, so the trail is there. If I sell to an EU company, a level of complication comes into play, because I have to obtain an EU registration number, and I can then zero-rate that transaction. On the other side, they have to do a reverse charge to recreate that VAT for themselves and claim it back. It is a burdensome system, whichever way we look at it. Whether or not a business is partially exempt, at the end of the day, the transaction looks the same, but it is not frictionless; it is far from it.

A big trader with transactions of more than £250,000 going out to the EU and more than £1.5 million coming in enters the ambit of the Intrastat system, which is quite burdensome. A business has to classify each and every commodity that it is selling abroad, according to an Intrastat classification nomenclature. If one were to look on the UK Trade Info website, they would find that there are literally thousands of lines of code. One really must ask whether this is bureaucracy gone mad. I was looking at the website as I was listening to the very worthwhile speech by my hon. Friend the Member for Ochil and South Perthshire. There is a different code for frozen lamb carcases and half carcases from frozen meat of lamb. One wonders why we have such a complex system.

This is all done electronically, and it comes down to trust. When we buy something in a shop, there is not a man from HMRC at the counter making sure that the transaction finds its way on to a VAT return, just as not every single transaction across EU borders is checked. But those records and proof of a good being transferred have to be maintained for six years. Again, this is not a frictionless system.

The issue of trust is very relevant to the Republic-Northern Ireland border. There are massive excise duties across that border. There are different currencies and a different VAT rate. Corporation tax is different, and income tax is different. There are a vast number of different things going on. I always give the example of the Jameson lorry that trundles from the Republic across the border into the north and perhaps then over to GB, and the Bushmills lorry going from Northern Ireland across the border to the south. There is no physical border infrastructure, yet there are hundreds of thousands of pounds of potential differences in the excisable duties. These lorries are never stopped, however, because there is trust, and that is the route to solving this problem.

Many people will say they have concerns about VAT losses across the border. There are such concerns, but again, this is based on trust. I consider that the amount of excise losses even today, during our membership of the European Union, must be of very great interest to the Financial Secretary to the Treasury. Let us just consider the cigarette trade, in which cigarettes come across the border from Poland at £2.50 a packet versus a UK cigarette price of about £10 or more, yet we accept those losses because individuals are allowed to bring in as many of these products as they please. That obviously feeds into a black market, and I can assure the Financial Secretary that those are just the cigarette trade excise losses. We have chosen as a country—for good or evil, but that is a debate for another day—that such evil products should have a very high rate of excise in the UK for health reasons, and we find that a good percentage of cigarettes for sale in the UK come in from other EU countries.

I am very pleased that my hon. Friend the Member for Ochil and South Perthshire mentioned that the US has a federal system. The US is often held up as the land of the free, as it is called, but I do not think that holds very true of Uncle Sam. The level of bureaucracy in running a business in the US is infinitely higher than in running one in the UK. I was quite intrigued to learn that if an individual in California decides to buy goods on eBay or whatever site they please from a low-tax state such as Dakota, they have to do a personal return for a transaction above a certain size monthly or quarterly, and actually return the equivalent of the sales tax—VAT, in other words—that the Californian authorities have lost because they have taken their trade outside California. These things are solvable.

I really wish the hon. Member for Strangford (Jim Shannon) was still in his place, because I understand the Northern Ireland concerns. As with anything in the profession of accounting or of running a business, when there is change, everybody puts their hands up in the air and says, “We’ll never get to grips with this. I’m retiring. I’m giving up. It’s all too complicated.” That applies to the real-time information for PAYE that we imposed some years ago—there were the same concerns—or auto-enrolment for pensions, but we get on with it.

[Luke Graham]

My hon. Friend is making a very strong point about taxation returns and the problems in Northern Ireland. Does he agree with me that some of the simplest solutions can be the best? Some of the best tax regimes are in places such as Hong Kong where there are flat taxes, which are simple and elegant. He talked about some of the complications in the US, which has a tax code that runs to some 75,000 pages, so it is said, whereas the UK’s had about 17,000 pages in 2015.

[Craig Mackinlay]

That is a topic for a wider debate, which I have often considered. The UK tax code does not have 17,000 pages; it has been rather well expanded to 22,000 pages. When we compare that with the tax code of Hong Kong, which runs to 350 pages, we can see the difference. When I was a councillor on Medway Council, we had a document on the localisation of council tax that ran to 370 pages. I wondered how on earth the entire tax code of a very successful and vibrant economy such as Hong Kong could run to 350 pages, yet Medway Council, which I served on, managed to get a 370 page document just to consider the localisation of council tax.

I know the Minister will want me to conclude, Madam Deputy Speaker, and I do not want to take up any more of his time, but the fact is that these things can be solved through the trust that exists today and the digital returns that exist today, including internationally. The concerns that our friends in the Democratic Unionist party have about a future trading bureaucracy are real, but once this is in operation, they will fade away, and people will get used to the new system within a very short time. I thank my hon. Friend the Member for Ochil and South Perthshire for bringing forward this debate, and I look forward to hearing from the Minister.

The Economy

Lord Mackinlay of Richborough Excerpts

Thursday 24th October 2019 Commons Chamber

[Sir Michael Fallon]

I certainly understand that, and my hon. Friend takes me to the point with which I wish to conclude, which is what more we can do to encourage share ownership. Some of the employee share schemes we have—I have written to the Chancellor on this—are still very complicated. The qualifying periods are still very long and do not reflect the mobility of the modern workforce. I am afraid some of the lower-paid staff simply cannot afford to participate in them. I hope that when it comes to his Budget, the Chancellor will keep looking at how we can do more to promote employee share ownership in particular, by reducing the qualifying periods and giving people a real incentive to save.

[Craig Mackinlay (South Thanet) (Con)]

Will my right hon. Friend give way?

[Sir Michael Fallon]

I am sorry but I will not; I am just finishing.

One of my heroes of the year—there may be many other candidates—is an entrepreneur called Julian Richer, who is now coming up to retirement and is handing over 40% of his company, Richer Sounds, to the employees, ensuring that they have a stake in the future. We need more incentives like that to promote loyalty and give people a real stake in their future. I thoroughly support the Queen’s Speech.

--- Later in debate ---

[Craig Mackinlay (South Thanet) (Con)]

I refer Members to my entry in the Register of Members’ Financial Interests.

Let us contrast where we are today with the background we inherited in 2010. We have unemployment down by 1.3 million—a 50% reduction from 2010. We have halved the number of young people who are out of work. We have made progressive increases to the national living wage. We have had a tax cut for 32 million through much bigger than inflation increases to the personal allowance, meaning that a basic rate taxpayer—the lower-paid—are paying £1,205 less in tax. Add that to increases in the national living wage, and the take-home pay—what lands in people’s bank accounts—is £4,000 more for the lower-paid, and that really matters.

We have reinforced our position as a world leader in financial services. That industry provides £127 billion of value added to our economy, paying £29 billion in tax and with a trade surplus of £61 billion. We have seen corporation tax reduced from artificially high levels of 28% to 19% today, and that will come down to 17%. That is a key driver in making sure that Britain remains a place to do international business and in keeping businesses that might consider going abroad in this country earning money for us. We have an infrastructure plan of the kind that we have never seen before to increase services on our roads and rail, and, of course, superfast broadband, on which we have been lagging behind for some time.

In the limited time left to me, I want to concentrate on our tax system. We need a debate about liberating our tax system to make sure that risk versus reward is properly in place and we do not penalise those who are willing to take risks and employ people to earn the money in the future. We have done very good work with the personal allowance, increasing it from the 2010 rate of £6,475 to £12,500 today. If we had had an inflation rate of 27%—on the figures during that period—we would have had a personal allowance of only £8,230, so we have got rid of the fiscal drag in that system. I am asking the Chancellor of the Exchequer, as he progresses towards his Budget, to consider the other aspects of fiscal drag that we have seen over the years.

For instance, on inheritance tax, the £325,000 limit has remained unchanged since 2009, whereas the house price index shows that house prices have increased quite substantially. We have had the main residence nil-rate band, but it has its complications, so this is a plea that we address fiscal drag across the system. We should treat tax not as though it is one move at a time; we need to play it strategically. We have done lots to improve the stamp duty system by getting rid of the rather hated slab system some years ago, but we are now seeing the additional 3% second property surcharge and, with the rates that exist at higher levels, a reduction in the tax take. We saw an increase in the tax take when we reduced the higher rate of income tax from 50p to 45p, and I propose that we can do the same with stamp duty.

I have advanced many of my proposals on capital gains tax to the Treasury, because I perceive there to be hundreds of thousands of properties stuck in second ownership owing to the application of penal CGT rates to those who own second properties but do not rent them out. We have a great opportunity to put our tax system back on the right footing—and please, please, let us not return to those old times when we penalised such people; let us support them.

No-deal Brexit: Short Positions against the Pound

Lord Mackinlay of Richborough Excerpts

Monday 30th September 2019 Commons Chamber

[Mr Clarke]

I am an historian rather than an economist, but I certainly do not take my lessons on hedge fund activity from Hollywood. We need to be very clear about the fact that there is a real need to provide certainty, and that certainty is hugely important.

Let me say gently—and it is gently—that I did not vote for the deal on the first two occasions when it came forward, for the very reasons that my right hon. Friend the Prime Minister did not do so, namely the concerns about the backstop provisions. Those provisions need to be addressed, and we are working to address them. Fundamentally, we did vote to leave, on a deal or no-deal basis. The hon. Lady’s constituents voted to leave the European Union. [Interruption.] The hon. Member for Stalybridge and Hyde (Jonathan Reynolds) says, from a sedentary position, “Not on a no-deal basis.” I find that my constituents are very clear about the fact that they voted to leave, deal or no deal, and that was very clear at the time.

[Craig Mackinlay (South Thanet) (Con)]

I congratulate my hon. Friend on his new position. He is truly doing sterling work this afternoon. It will come as no surprise to him to learn that I am fully in favour of well-run and smooth capital markets, from which London is reaping an international reward. Would he care to speculate on what sort of short-selling and sterling damage would be done under the Labour party—given their unfunded tax proposals and their potential sequestration of public assets—and what the market would think of them if they were anywhere close to power, which I pray that they will not be?

[Mr Clarke]

My hon. Friend is absolutely right. I am afraid we cannot get around the fact that we are now dealing with something very dangerous in terms of the division between the two parties: the division between economic rationality and a programme that would well-nigh destroy the free-market economy in this country. [Interruption.] Labour Members scoff and sneer, but the reality is that anyone looking at the prognosis from the Labour party conference last week—let alone the trillions of pounds of commitments that Labour is now adding up—will see that it would not only destroy our public finances, but would do massive damage to the competitiveness of British business, on which jobs and homes and mortgages depend.

High-income Child Benefit Charge

Lord Mackinlay of Richborough Excerpts

Tuesday 3rd September 2019 Westminster Hall

[Craig Mackinlay (South Thanet) (Con)]

I beg to move,

That this House has considered the high-income child benefit charge.

It is always a great pleasure to serve under your chairmanship, Mr Hollobone.

One might ask why I have brought this debate; it is a fairly obscure area of tax and benefits. I have done so out of the frustration felt by a number of constituents who face the high-income child benefit tax charge and its after-effects and, as a chartered accountant and chartered tax adviser, anything tax-related always rattles my bell. This is a topic of great interest on mumsnet.com and moneysavingexpert.com, which have covered the issue in some depth.

I suppose we must start at the beginning—always a good place to start. Why did we implement this high-income child benefit tax charge, when child benefit had been a universal benefit, enjoyed by all, for very many years? The issue was first raised in October 2010 by the then Chancellor, George Osborne, and it was one of the measures used to try to get some more savings for the Treasury after the simply appalling state of the nation’s affairs that we were left with after the 2010 election.

The legislation was first mooted in the 2012 Budget, and it came into effect on 7 January 2013. That in itself was a bizarre date to choose, and one might ask why it was not simply started on 6 April in the next available tax year, which might have made life a little simpler. I have not found figures for how much the clawback and the lack of take-up of child benefit have saved the Treasury, but I estimate it to be somewhere in the region of £2 billion to £3 billion a year—certainly a very useful amount to fill up the hole left by Labour in 2010.

The charge applies above an adjusted net income of £50,000. Adjusted net income is not the usual measure of what we anticipate to be our taxable profit or income; it is the gross income from all sources, less gift aid and pension contributions. It does not include personal allowance. In very simple terms, if a pay-as-you-earn employee has a gross income of £50,000 before personal allowance, they would start to feel the effects of the high-income child benefit tax charge.

The way it works is that there is a clawback of 1% of child benefit for each £100 of additional income over the £50,000, so by the time someone has an adjusted net income of £60,000, all that child benefit is tapered away. It sounds complicated even trying to lay it out in the simple terms that I have, but one thing that comes out of this is that it is a salutary lesson in how not to withdraw a universal benefit through the tax system. What we have on the statute book, which runs to many tens of pages of tax law, is the truly mad basis of trying to claw back a benefit. It is not related to overall family income, which many people describe as one of the real drawbacks of the system.

Let me give an example. Family income is recognised as the measure for most other Department for Work and Pensions benefits. For instance, there is no withdrawal of child benefit for a couple both earning £50,000—the high-income child benefit tax charge does not apply, even though the family income is a generous £100,000. In another family, in which only one parent is working and earning, say, £60,000, and the other is not working, there would be a full claw-back of the child benefit given. That makes life complicated for people on pay-as-you-earn, who can do nothing about their income, and there is also the issue of fairness. Family businesses, or people in sole trade, perhaps have a greater opportunity for sharing income, splitting income or indeed creating a partnership to split the income down to the golden £50,000, so that there is no loss of child benefit.

I feel that this situation has led to an inherent unfairness in the system, which is one of my concerns. My other concern is the means of collection, and there lies the problem that we have faced. People who recognise that they will not qualify for child benefit can choose simply to disclaim the benefit and not receive it at all. That has been on the rise over the years since the charge has been in place. In 2013, 397,000 people were not claiming the benefit, and the number has now increased to 516,000. That is due to two issues, one of which is fiscal drag—the level has not been raised since January 2013, which is something I will raise later.

Some people are happy and feel that it is to the family advantage to maintain their cash flow—get the money into their bank with the monthly receipt of child benefit, then simply pay it back at the end of the year. Some people do that. However, the real madness in the system—we should have tax systems that make things easier—is that the implementation of these measures forced 500,000 more people into the requirement to fill in a self-assessment tax return. It is a huge bureaucratic cost to taxpayers, and managing the system must also be a significant cost to Her Majesty’s Revenue and Customs. It is the root of the problem of collection.

Many PAYE employees have had never had to touch the tax system or fill in a self-assessment return. Luckily for them, they have been merrily ignorant of anything to do with tax. It is all done at source by their employers—if they have no further complicated tax affairs, they need do no more. The current situation has been a particular hardship for these taxpayers. They might not have spotted the advertising that was fairly extensive at the time. They perhaps received less than £50,000 at the time, but over the years their income has crept over that figure due to wage rises and better business.

I have raised this issue for a couple of my constituents and pursued it with great vigour. I have argued with HMRC that the information about which PAYE employees would face this charge is well known to Government through the real-time information system of payroll that bigger employers have had to implement since April 2012, and was rolled out gradually over time to all employers, even the smaller ones, running a PAYE system. The information was available—primarily to the DWP, so that it can assess whether people in receipt of benefits should not be, but HMRC had access to the system.

I have failed to agree with HMRC’s stance on this. It claims that the arm of Government dealing with the DWP has got no relevance to their arm, which deals with tax. The data has not been shared, even though the arms of Government had the information at their fingertips and could have advised people that they were potentially falling foul of the system. In my arguments to HMRC on behalf of my constituents, I argued for extra-statutory concession A19, which is often used when HMRC makes a mistake—often with the elderly. I saw this very regularly when I was one of the volunteers for Tax Help for Older People in Kent. HMRC has had the information and applied the wrong code across different pensions. Three years later, an assessment turns up. Extra-statutory concession A19 makes HMRC give up that tax if it has been in receipt of information but has not used it properly.

Of the constituents who have been found not to have done what they should have done—registered to do a self-assessment return, possibly for the first time in their life—they have been, well, not happy, but comfortable enough, even given what ESC A19 says: that they should pay the money back. They are quite happy with that. However, many of these people have faced a tax-geared penalty under section 97 of, and schedule 24 to, the Finance Act 2007. That penalty has generally been at the lowest rate of 15% under the careless but prompted regime, under HMRC’s fines regime. However, they have also faced statutory interest, which is currently at 3.75%. Many people understand that, if they have been in receipt of child benefit for a few years and should not have been, they should pay it back, but they feel particularly aggrieved about a 15% penalty and the statutory interest.

I argued with HMRC, for my constituents, that the suspended penalty regime, under paragraphs 1 and 14 of schedule 24 to the Finance Act 2007, should be the equitable solution. This is a procedure by which HMRC, with discretion, is allowed to put those penalties on hold and effectively say, “If you are good taxpayers for the next couple of years, this will disappear”; the penalty is then discharged. HMRC responded to me with, I must say, an innovative obtuseness that I rarely see. It responded that schedule 41 of the Finance Act 2008 applies, as the taxpayer had failed to notify, in accordance with section 7 of the Taxes Management Act 1970. They had failed to notify, so that penalty suspension, which is allowed for other taxpayers, does not apply. The taxpayer is also in some difficulty should they wish to go to the first-tier tribunal as well, which would always result in failure on a statutory basis.

I think the pressure of mumsnet.com, moneysavingexpert.com and, hopefully, myself has made HMRC use a degree of discretion in its ability to interpret “carelessness”, which is always a vague term. My thought of carelessness might be different from yours, Mr Chairman. However, HMRC has gone back and reassessed many penalty assessments. Over the time of this new charge, there have been 97,405 penalties across 37,406 customers. As ever, thanks to the Library for pulling out that type of detail for me. The charge has raised £15 million of penalties, which is not a vast sum. A recent review—I think the Daily Mail was very much behind this, with pressure from some of its readers—shows that, of those 35,000 cases involving a failure to notify, a penalty of 15% had been charged because a reasonable excuse was not accepted. HMRC has actually recanted on that and allowed quite a number of thousands—6,000, I believe—of these penalties to be waived, with £1.8 million of penalty refunds.

As part of its work, HMRC has designed a helpful flow diagram showing two events for which penalties could be refunded. The first is for when income has increased from below £50,000 to above £50,000 since the start of the high-income child benefit tax regime, and the second is for when a taxpayer has started a new relationship, since the introduction of the charge, with a partner who is in receipt of child benefit. Those are the two cases for which HMRC has given in and agreed to the suspension of penalties, and that is to be very much applauded.

What do people do when they have a new child and make a claim? If they know that their income is over the limit, they may not bother at all—they might think, “We just won’t get involved.” For other families there is the CH2 form, which I will mention in more detail shortly. As I have laid out thus far, we have dragged half a million people into the self-assessment net. We have raised penalties under a system that I do not agree is reasonable on statutory grounds. We are learning a lesson: should we seek to withdraw universal benefits in some other field—that suggestion is not on the Conservative agenda, but it is raised from time to time, for example with winter fuel allowance—this has to be a salutary lesson in how never to use the tax system to withdraw benefits.

I will conclude by addressing five areas, which might take a little time. We have fiscal drag, because the thresholds at which the full benefit is withdrawn—namely £50,000 and £60,000—have applied unchanged for six years. We now find that as wages rise, more people are dragged annually into self-assessment. Since its inception in 2013, 370,000 more families have to fill in a self-assessment return.

I am very surprised that the House did not pick up at the time on the fact that the system completely blows away the independent status of taxation for couples. Even up to 1990, women were deemed to be the chattels of their husbands, and there was a single tax return. In 1990, that was thankfully blown away, having been overdue for a long time. I think the groundwork was laid by Geoffrey Howe and seen through by Lord Lamont. After that date, people were treated as they should be for tax: as individuals.

The system blows that away because one partner now needs to ask the other, “What do you earn, because I need to determine whether it is you or I who pays the high income child benefit tax charge?” The partner in receipt of the child benefit might not be the one paying the charge; it always falls on the higher earner. Whereas before there was decent independence and secrecy between partners should they so wish, that was blown away by the legislation, and I do not feel that could ever be right.

Subsequent tax legislation has also had an unusual and, I think, unforeseen impact, including, particularly, on buy-to-let property. At the start of my speech, I mentioned the concept of adjusted net income, which is income from PAYE, rents, dividends and whatever else one might receive. Changes to buy-to-let allowability of mortgage interest, however, have had an unforeseen impact. Years ago, rental income less expenses and mortgage interest would give a net figure, which would form the top end of the tax return and be part of the creation of the relevant net income. With the gradual restriction of the allowability of mortgage interest—I will not expand on whether that is right, wrong or indifferent—the tax return looks different. Net relevant income for rental purposes does not include the deduction for mortgage interest, which now comes at the bottom part of the tax return. Instantly, the net relevant income at the top part of the tax return is now bigger for many people with mortgage interest, even though the net effect for cash flow and everything else might be the same. There is now some relief for mortgage interest at the bottom part of the tax return, by way of a credit of tax.

I did not see the full shortcomings of that piece of legislation at the time, even though, at that Budget statement some years ago, I raised concerns about changing the whole deductibility regime, which is fundamental to tax. That legislation has caused another group of families, who are doing nothing particularly exotic, to be dragged into the high income child benefit tax charge, as their income has pitched into the £50,000-plus bracket because of the deductibility of mortgage interest, even though nothing has changed.

A real concern shared by all hon. Members in the Chamber is that of the Women Against State Pension Inequality Campaign. They have been active because they have an axe to grind and I think that many of us have sympathy with some of what they have to say. We are potentially building another problem for the future—thankfully, I might be long gone from this place before it has to be solved.

Earlier I described what people might do when they have a new baby. If they have earnings of more than £60,000, they might think, “I just can’t be bothered to fill in the form. I’m not going to get anything; why would I bother?” The CH2 form is not unreasonable or too complex—it is actually quite free flowing and easy to understand—but a lot of people do not bother at all.

The other choice they have, by filling in form CH2, is to take the child benefit and then pay it back annually through their self-assessment return, or to register for a nil award so that they are in receipt of child benefit but at nil value. That is really important for those who do not follow that route. They do not want the hassle of a self-assessment return, so they decide to do nothing. The partner in that relationship, who is perhaps not working, will not be building up a national insurance record, because if someone fills in form CH2 and decides not to take any child benefit, they will at least be crediting up a national insurance contribution under class 3. My concern is that people do not know that this is there for them and are saying, as many of us do, “I can’t be bothered to fill in another form. I don’t think I will get anything. I won’t do it.”

We are potentially building up a problem of people—let us be frank, it is probably predominantly women—who will find in the future that they do not have the national insurance record that they thought they had. When they get their DWP statement with details of the award they will receive with the new state pension some six months before retirement age, they will find it is rather less than they thought.

We have to ask ourselves why we have dragged 1.2 million families into the system—and that figure is rising, due to fiscal drag and the measures for buy-to-let property mortgage interest. It is worth mentioning the perversities in the whole tax calculation. I do not know how Parliament missed that. I was not here in 2013, but had I been I might have spotted it. It is an unusual situation, but when dealing with tax systems, I think it best to flex the edges to find out where the problems are.

This is an extreme case, but it is catered for on the gov.uk website: in 2019-20 a family with 10 children—there are not too many of those around—would be in receipt of £7,500 of child benefit. Anyone earning £50,000, including a self-employed person, would be in receipt of £7,500 in child benefit, but if they had the opportunity of a great new contract to get their income up to £60,000, under this system they would have to pay back that entire £7,500. In my view, tax lost—tax paid—and benefit lost are the same thing. What lands in someone’s bank account is the same thing, whether that is through losing benefit or paying more tax. In effect, therefore, for that extreme example of a family, there would be a 75% clawback charge, because they would pay back the £7,500 child benefit owing to that £10,000 in additional income.

That is not where the matter ends, of course. People who earn £50,000 are higher-rate taxpayers, paying 40% tax and, if employed, 2% national insurance. We therefore have the perversity, which I am sure is not always seen, of a 117% tax charge and benefit loss. For that extra £10,000, that taxpayer will actually be worse off by £11,700. There should not be such perversities in the tax system.

I like a debate to end with a solution, but there is no easy solution to this one—I grant the Financial Secretary that great problem. I would like to extend the penalty suspension to all, because I think HMRC has been rather obtuse about this one. If people start to do the right thing, past penalties should be suspended and, if they do the right thing for the following two years, those penalties should disappear.

The easier option would be to restore the universality of child benefit. Nothing is simpler than that—everyone gets it without means testing or complication—but the Government and the Treasury understandably want to claw back that benefit from people in receipt of higher income. A complicated solution—or, rather, a politically difficult one—would be to reduce the personal allowance for those with children. They would get their full child benefit but pay a little more in tax. At least that could be coded out—they need not worry about the self-assessment system—and for the PAYE taxpayer with simple affairs, things would be just as they are. However, that would be a difficult way to do it.

It would be simpler, perhaps, to make a higher universal child benefit payment, which this year is £20.70 for the first child and £13.70 for subsequent children, subject to the benefits cap. Any increased child benefit, however, should be made a taxable benefit. Therefore, through coding, the Government could claw back 20% from a basic rate taxpayer, and 40% from a 40% taxpayer. For those with complicated tax affairs, adding the layer of clawing back the high income child benefit tax charge is no great difficulty. Something similar happens already. The retired have a simple coding adjustment for private pensions to reflect the level of their state pension.

We need a new and elegant solution, and to learn the lesson that whenever Governments in future claw back benefit, they should not do it in this way, through the tax system. It has created bureaucracy and angst, and I am worried that normal, law-abiding taxpayers now feel that they have done something very wrong because of those levels of penalties. That is my appeal to the Financial Secretary.

--- Later in debate ---

[Craig Mackinlay]

I am delighted to have the final say. I thank hon. Members who attended the debate. There were contributions from the hon. Member for Strangford (Jim Shannon), as ever, as well as the hon. Members for Glasgow Central (Alison Thewliss) and for Oxford East (Annelise Dodds). We spar regularly on tax matters across whichever Chamber we are in, but I think we are broadly in agreement that the system is complex, that it could have been made easier and that there are problems that need to be solved.

I am pleased to receive a degree of assurance from the Financial Secretary to the Treasury. He accepted that the charge was a measure of its time, when urgent measures were needed to respond to the state of the country’s finances. It has not been part of my argument that such a clawback should not exist. My observation has been that, if we are to have methods of clawback, we need to design systems that are more elegant than this one. I hope he will pass on to HMRC my issues regarding the penalty regime. Perhaps this can be the last of it, with people made aware that, yes, if they do wrong in the future, a penalty regime may apply. However, I would like to see a softer touch, given the modest amounts involved, for those stuck in cases at the moment.

Question put and agreed to.

Resolved,

That this House has considered the high income child benefit charge.

NHS Pensions: Taxation

Lord Mackinlay of Richborough Excerpts

Monday 8th July 2019 Commons Chamber

[Elizabeth Truss]

The answers to the problems within the NHS lie within the Department of Health and Social Care, which is why the Department is launching a consultation. As I said earlier, we need to make sure that the pension tax system is designed around all employees. Of course NHS employees are extremely important, but we need to make sure the system works for all employees. That is a longer-term task, but we are specifically looking at the 50:50 idea in the consultation. No doubt the Health Secretary is talking about other ideas that could be introduced, and I am sure he is very interested in the right hon. Gentleman’s views, too.

[Craig Mackinlay (South Thanet) (Con)]

We have created the most unbelievably complicated tax system. If working additional time makes the pension pot larger, there could be a 55% tax charge when taking those surplus benefits, and restrictions on the annual allowance are resulting in these large tax bills.

It is not surprising that many health professionals are choosing not to do the extra work or are simply retiring earlier. My right hon. Friend the Member for Wokingham (John Redwood) makes a key point, because extra earnings would take many of these people into the slice above £100,000 to £125,000, where a 62% tax charge applies.

This is not just an NHS problem. My concern is that we are putting a brake on those entrepreneurs who want to create enterprise, jobs and the tax payments of the future. A simple step would be to get rid of the lifetime allowance.

National Insurance Contributions (Termination Awards and Sporting Testimonials) Bill

Lord Mackinlay of Richborough Excerpts

2nd reading: House of Commons & Ways and Means resolution: House of Commons
Tuesday 30th April 2019 Commons Chamber

[Craig Mackinlay (South Thanet) (Con)]

It is always a pleasure to follow the hon. Member for Aberdeen North (Kirsty Blackman). The two of us often seem to be in the Chamber at a similar time discussing tax issues.

These measures have been a long time in process. Back in the Budget of 2016, there was talk of a consultation on trying to align more closely national insurance with tax treatment. I note that, today, the Exchequer Secretary to the Treasury said that this is a form of simplification of the tax system. I might disabuse him of those thoughts by telling him to look more closely at the new rules regarding post-employment notice pay within payments in lieu of notice as part of termination payments. Far from being simple, it is actually rather complex.

As I said at the very start, these proposals have been making their way through this House in various forms. There were some delays because of the unexpected election in 2017, but they did find their way into a draft Bill in December 2016—the National Insurance Contributions Bill. Some proposed changes came through in the 2017 Budget, which included the scrapping of class 2 national insurance for the self-employed—currently £3 a week—and a corresponding increase in class 4 national insurance contributions for the self-employed. They were highlighted as fairly controversial at the time, but I did not share that view. I was quite supportive of the increase in class 4 national insurance because of the generosity, as I saw it, of the new state pension that came into play. That slight increase in the class 4 national insurance rate was, I felt, a fair quid pro quo for the quite substantial increase in the new state pension, but, for whatever reason, that measure was not taken through. I had some serious concerns about scrapping class 2 national insurance, and I will explain why.

The lowly paid self-employed person may not hit the threshold for class 4 national insurance contributions, which is, I believe, something above £8,500, but is more likely to have paid class 2 national insurance contributions and so would be ticking up a national insurance record into the future. Given that WASPI women have concerns about where they find themselves today, I was worried that this House and future Members of this House—I will probably be long, long gone—would face a raft of new people saying, “Where’s my pension. I have been self-employed all these years.” They would then be told, “Ah, but you didn’t pay any national insurance; you didn’t pay class 2, and you certainly weren’t earning class 4.” I was pleased to see that that idea disappeared and that we are back to what was the old system.

We have had this £30,000 threshold for tax-free redundancy payments—let me put it in easy terms—for quite some time. It could be argued that we have been at that level of £30,000 for too long. I did a bit of research before today and found that the last time that the £30,000 threshold was raised was with effect from 6 April 1988. It must have been considered to be the right rate at the time—it was an increase in rate from £25,000 to £30,000. I did not manage to find out when the £25,000 rate was first implemented, but it must have been deemed at the time to have been the right rate for what was a tax-free settlement, or payment, for years of service within a company. It was obviously deemed to be the right amount for people to adjust to a new work situation, or to act as a bridge towards retirement for people who were getting towards the end of their normal working life, which was perhaps more traditional in those days of the ’80s. I know the hon. Member for Bootle (Peter Dowd) raised some of those points in his speech.

Having consulted the Office for National Statistics for inflation increases since 6 April 1988, I found that £100 then is now worth £266 today. Applying that inflationary increase from 1988—no more, no less—that £30,000 would inflate to £79,800, or in broad terms £80,000. However, I do understand—for the record I am a member of the Chartered Institute of Taxation and a chartered accountant—that there is probably a perception that the £30,000 settlement payment has been a target to hit rather than a proper target for any other reasons. Hence we now have this fairly complicated formula for payments in lieu of notice. Changes came in on 6 April 2018, including this whole concept of post-employment notice pay. It was really to recognise the difference between contractual payments in lieu of notice and non-contractual payments in lieu of notice. I will not bore the House for too long with the formula that applies, but it is a fairly beefy one: it is basic pay multiplied by the number of days from the last day of employment, divided by the number of days in the last pay period, minus the amounts paid on termination—a formula given the letter T. Therefore, far from it being a tax simplification measure, the PILON rules have added quite a layer of complication to a figure of £30,000 that, in due course, should have been given adjustment for inflation in any effect.

We are now left with PILONs—the new PILONs assessment of what they are actually worth—holiday pay, and any restrictive covenants being included within that £30,000 limit that is tax free and national insurance free. Above that, we have the normal rules of tax and— in complex speak—employers’ class 1A national insurance coming into play. What we are likely to see in terms of adjustment, in answer to the hon. Member for Aberdeen North, is an increase in employer contributions to pension schemes as part of a settlement on the way out, which is not any bad thing. There is nothing wrong with that.

We have a very powerful and strong message to tell about auto-enrolment. It must be the right thing for all employees now. We are now running into millions, and there will be a fund approaching tens, if not hundreds, of billions in due course, and that must be to the good, as people accumulate their own pension funds. We will look back at auto-enrolment and see it as one of the most successful and vital measures that any Government could have implemented. It is like any other measure. It sounds expensive—it means a percentage off salaries, which will always be unwelcome particularly in times of low inflation, and it means that people might see their take-home salary go down—but there will be a lot of thanks from many employees in due course that these funds have been accumulated. If, in trying to circumvent, in an entirely legitimate way, paying the class 1A national insurance on these amounts—for normal employees over £30,000—employers provide more funding to a pension scheme, then that is something as a quid pro quo that the Treasury should actually support.

These measures should have come into play in April 2019. They were deferred last year for a further year, which is mentioned on page 42 of the official Red Book. Therefore, far from saying that these things have come out of the blue and have not been considered, they have been consulted upon since 2016. They nearly got somewhere, but were deferred for another year. Therefore, in terms of planning and getting that together, there is plenty of time for employers to make any due adjustment. I have really concentrated on part 1 of the Bill.

Let me turn to the sporting side of things and the £100,000 limit. There have been a lot of discussions on this subject, because we are talking about huge figures, especially when the very well-known sports stars have their testimonials. When there are millions of pounds involved, these people—who are already very wealthy—often decide to give all the money to charity, which is a laudable ambition. I suppose that the one downside of this type of legislation is that it is possible for the employer in such cases to suffer the national insurance on an amount that the recipient has never actually received because he or she has decided to put it through their tax return as a very generous donation to charity.

This subject brings out the debate about certain limits in our tax regime that have not been touched for a very long time. What was the purpose of the £30,000 threshold? There was a reason for it in 1988, but does it still apply in the modern employment market? Perhaps people do not work as long for the same employer now; that feature is probably slightly different today from how it might have been in 1988. What should the figure be? Does it deserve flexing up? We could have a similar debate across other bits of the tax code—perhaps including inheritance tax.

Lots of parts of the tax code have fallen behind inflation. They were originally there for a reason. Some were introduced when the Labour party was in government, but now that we are in government perhaps there is a debate to be had about what these things were for in the first place, as part of the tax simplification process. But if there is any fear or threat that there has been manipulation of the tax and NI system, it is right that these payments should be part of the normal weft and weave of what we are doing with national insurance. I therefore have no difficulty supporting the Bill, and I wish the Exchequer Secretary to the Treasury every success in its progress through the House.

Business Rates

Lord Mackinlay of Richborough Excerpts

Tuesday 2nd April 2019 Commons Chamber

[Sir Geoffrey Clifton-Brown]

I well remember meeting my hon. Friend for the first time in the Eight Bells pub in 1997, when we were both a little younger—[Interruption.] She says, in parentheses from a sedentary position, “better looking”—I was not going to say that in case I came within the bounds of the code, which I think might well touch on the sort of remark that I might make. Nevertheless, I wholly concur with her sedentary remark.

[Craig Mackinlay (South Thanet) (Con)]

I put on record that I have been trying to take action for a number of years to exempt public conveniences from business rates. Especially in respect of the towns in my constituency—Ramsgate, Broadstairs and Cliftonville are tourist areas—I have always said that public loos are often the first thing that people use and the last thing that they remember, and they should be thus exempted.

[Sir Geoffrey Clifton-Brown]

I am sure that the tourists in my constituency will be greatly relieved to hear what my hon. Friend has to say. In my constituency, which is very dependent on tourism, I have been having a big battle with the local council to keep public conveniences open, because it is really important. If someone comes for a day’s outing to the Cotswolds or goes to my hon. Friend’s constituency, they cannot last all day. They need somewhere to go, and I was delighted when the Government gave that sort of relief.

Taxation (Cross-border Trade) Bill

Lord Mackinlay of Richborough Excerpts

3rd reading: House of Commons & Report stage: House of Commons
Monday 16th July 2018 Commons Chamber

[Ian Murray]

I am delighted to hear that he would have resigned regardless, but he must surely have some regret. Perhaps we should be glad that he resigned, given that he stood up in this Chamber, as a former Secretary of State, and tried to persuade the House that Operation Stack and having trucks and lorries queued up at our ports was positive for the country. I have never known a former Secretary of State to look at something like Operation Stack, which would be a tragedy for our economy had it continued for much longer, and turn it into a positive. If that is the kind of argument he is offering to this House and to the country, we should ensure that we vote down most of these amendments.

I find it extraordinary that after going through this process—these debates give me déjà vu—we are still hearing arguments about the customs union and the single market. The Government managed to botch together what is now called the Chequers agreement and now, a week away from this Parliament adjourning for the summer recess, they have completely torn it apart by again pandering, as the right hon. and learned Member for Rushcliffe (Mr Clarke) said, to 30 or 40 people on the hard right of the Conservative party. Those people would be being much more honest if they just stood up and said that they want the cliff-edge hard Brexit, rather than tabling amendments that drive a coach and horses through the agreement that the Government managed to reach.

[Craig Mackinlay (South Thanet) (Con)]

Is the hon. Gentleman really suggesting that the 163 independent members of the WTO are somehow teetering on a cliff edge or doing something rather odd? Are they not just normal trading nations that trade freely with each other? I find his “cliff edge” statement rather peculiar, because it does not treat the facts.

--- Later in debate ---

[Nic Dakin (Scunthorpe) (Lab)]

I apologise for the fact that I had to attend a Statutory Instrument Committee, but I was present at the beginning and I am here now. It is a pleasure to follow the right hon. Member for Chelsea and Fulham (Greg Hands), who brought us back to the detail of the Bill, which is where I wish to focus my remarks.

I was concerned that the proposed dumping methodology might not address the UK steel industry’s concerns, so I am pleased that the hon. Member for Stafford (Jeremy Lefroy) has tabled amendment 25. I am also pleased that the Government have engaged with Members from all parties and that last week, in response to a written parliamentary question from the hon. Member for Middlesbrough South and East Cleveland (Mr Clarke), they underlined their commitment to

“protecting UK industry where it is suffering injury as a result of dumped imports.”

The Government went on to say that they would not allow that to happen and would use mechanisms for the calculation of dumping methods that, on the face of it, seem to have the support of industries such as steel and ceramics. I very much welcome the fact that the Government have listened and have worked with key industries during the Bill’s progress through Parliament.

I am less convinced by the situation in relation to the economic interest test. I was rather hoping that, in line with the rhetoric that we heard throughout the whole argument for leaving the European Union, we would take advantage of the opportunity that leaving the European Union offered to reduce any bureaucratic pressure on industries such as steel, rather than adding to their bureaucratic pressures. The economic interest test in the Bill adds extra layers compared with what currently exists in the European Union, so we have the genius of a Government bringing forward something even more complex than what we already have in the European Union. I did not think that was the purpose of what we were doing; perhaps I was naive.

In Committee, we expressed concerns about the proliferation of economic interest tests that have been built into the regime and that measures must pass before tariffs can be introduced. Of particular concern was the fact that such tests will first be conducted by the independent Trade Remedies Authority and then again by the Secretary of State, theoretically on a completely different basis. As such, we have pushed for the Secretary of State’s power in relation to the tests to be curtailed and at most to act as a sense-check on what the TRA has conducted. Anything more than that will introduce an unacceptable level of potentially political interference into the process. It will be an unnecessary block on what is happening. The real worry is that it will delay the introduction of trade remedies and thereby potentially subject industry to more damage. However, the Government have tabled amendments 103 and 108, which go some way towards addressing the concerns I have just outlined.

Government amendments 110 to 112 and 116 to 118 seek to deal with the replication of tests, but they would not do that sufficiently well, so I shall support amendment 21, tabled in the name of the Leader of the Opposition, which would achieve a better outcome.

Finally, let me say a little about safeguard measures and adjustment plans. I am concerned that the Government intend to require any industry that requests safeguard measures to submit adjustment plans to demonstrate how it will adjust to new market circumstances, before any safeguard investigation can be launched. In essence, that would require an industry to demonstrate what changes it was making to its operations, including efficiencies and rationalisations, before a safeguard investigation could even start. UK Steel and others have pointed out that in situations such as those we currently face in relation to US section 232 tariffs, such a requirement would be unjustified. Industry should not have to make major adjustments to deal with what is likely to be a temporary situation introduced by the non-WTO-compliant actions of another Government. I am therefore pleased that the Government have tabled amendment 113 to modify the requirement, allowing the TRA to waive the requirement when it deems it necessary or suitable. It would, though, be better if that pressure on industry—at a point at which it is already under significant pressure—were not there.

I wanted to put those concerns on the record so that the Government have the opportunity to make further improvements to the Bill as it makes progress in the other place and before it comes back to this House.

[Craig Mackinlay]

I rise to speak to amendment 73, tabled in my name and the names of my right hon. and hon. Friends, and which I wish to move at the appropriate time.

It now has to be a settled will that in future we are not going to be in the, or a, customs union with the European Union. That became clear during the hours of debate on the European Union (Withdrawal) Bill in this place and the other place, and that Bill became an Act. It is clear in the Chequers deal and the White Paper on the future relationship. The statement “We will not be in the customs union” has passed through the Prime Minister’s Lancaster House and Mansion House speeches, and through her statements on the Floor of the House on occasions far too numerous to mention.

We are not to be in a customs union. That was clearly the compact with the public made by the Conservatives and the Labour party in their manifestos last year. It is clearly the will of the people, as expressed in the June 2016 referendum. I do not think there can be any doubt about the clarity, because it was mentioned by all involved in that debate, no matter what side they supported. It is clearly the will of the people, of the Prime Minister and of the Cabinet. Similarly, when we negotiated and passed the European Union (Withdrawal) Bill, it was the will expressed by a majority of this place.

My hon. Friend the Member for North East Somerset (Mr Rees-Mogg) said earlier in an intervention that, were it necessary for there to be a customs union with some part of the world, there would need to be, at the right time, primary legislation that would also incorporate any requirements in the Government’s proposed new section 16A, which I am trying to nullify with amendment 73. I certainly hope that, given those settled wills, my amendment will be supported by the Government because anything else does not square with the manifesto on which we were elected and it certainly does not square with the manifesto on which the Labour party was elected either.

--- Later in debate ---

[Mr Leslie]

Will the hon. Gentleman give way?

[Craig Mackinlay]

I will; I would enjoy continuing my speech so please intervene.

[Mr Leslie]

Did the hon. Gentleman notice that, in March 2016, the European Union agreed, on the so-called tampon tax issue, to allow zero-rating? Therefore, the point that he made is completely debunked.

[Craig Mackinlay]

I am sorry, but that must have passed me by. I know that, to get around the difficulties that were caused by the tampon tax and the significant debate that we had in this Chamber, of which I was a part, the Government agreed to sort of equal the amount that was collected to pass it to charity. So it seems bizarre that we have not taken the steps that are available.

The other thing about going along with the VAT directives and how VAT is managed is that we have been subject to the missing trader intra-community fraud, the so-called carousel fraud, which cost this country £1.7 billion last year. It is estimated to cost the EU as a whole into the tens of billions of pounds. Over the period of the administration of VAT in its current form, it could have cost anything up to £100 billion across the EU. Are we really saying that these failed systems are something that we want to be attached to in perpetuity?

The Prime Minister has said very clearly that we will be in control of our tax policy. Just last week, following Chequers, the Secretary of State for the Environment also confirmed that we cannot actually set our own taxes as we would wish to at the moment because VAT is set in accordance with EU rules. That is another area in which we will be sovereign. Amendment 73 would make sure that, no matter what the future holds, primary legislation will be needed to do this. We cannot have the vestiges of some of the worst VAT rules that anybody could ever imagine remaining on our statute book. For that reason and given that powerful debate on the tampon tax, I certainly hope that others across this House will support that amendment this evening.

[Mr Speaker]

Has the hon. Gentleman completed his oration?

[Craig Mackinlay]

indicated assent.

[Mr Speaker]

He has. We are grateful to him.

Oral Answers to Questions

Lord Mackinlay of Richborough Excerpts

Tuesday 3rd July 2018 Commons Chamber

[Mel Stride]

The simple fact is that we need an HMRC that is fit for the 21st century, for the new digital ways in which we are working, and for our targeted approach on clamping down on avoidance, evasion and non-compliance, for example. That requires these sophisticated hubs that have the right skills to do that job, so I defend our reorganisation entirely.

On the portrayal of the economy that the hon. Lady has just given, we have the highest level of employment in our history, more women in work than at almost any time in our history and unemployment lower than at any time in the past 45 years. We are bearing down on the deficit and have debt falling as a percentage of GDP.

[Craig Mackinlay (South Thanet) (Con)]

13. What steps he is taking to invest in infrastructure in Kent.

[The Economic Secretary to the Treasury (John Glen)]

The Government are committed to ensuring that every part of the country has a modern and efficient infrastructure. In Kent, the extent of superfast broadband has risen from 33% to 95% since 2010, and the South East local enterprise partnership has secured £590 million for 30 transport schemes. Work has recently begun on a £105 million upgrade to junction 10a of the M20.

[Craig Mackinlay]

Given that Kent is on the frontline of EU border trade and that local plans involve the potential of more than 100,000 new homes over the next 15 years, will my hon. Friend consider investing in the dualling of the A2 and the A256 to improve traffic flows and resilience in east Kent?

[John Glen]

My hon. Friend makes a very sensible point. The dualling of the A2 near Dover was raised as an issue in Highways England’s route strategy for Kent and is being considered alongside other investments. The A256 is part of the indicative major road network and the Department will be publishing the final network by the end of the year. If it is included, it will be a matter for the local authority, working with the subnational transport bodies, to determine whether to bid into the fund.

Oral Answers to Questions

Lord Mackinlay of Richborough Excerpts

Tuesday 22nd May 2018 Commons Chamber

[Elizabeth Truss]

What we have seen in the past few years, since 2015, is a 7% rise in the real wages of people on the lowest incomes, and a reduction in income inequality.

[Craig Mackinlay (South Thanet) (Con)]

T8. With the full phasing in of the residents’ nil-rate band for inheritance tax by 2020, a couple will potentially be able to leave £1 million free of inheritance tax to descendants. That is all very welcome, but having worked through the legislation in a real example, it seems unduly complex. Will my right hon. Friend now consider simplifying the law to make the overall IHT allowance a simple, no-nonsense £500,000 each and remove the complexity of the residents’ nil-rate band rules?

[Mel Stride]

My hon. Friend talks about complexity. The Office for Tax Simplification is looking into the way in which inheritance tax and the regime operate. Changing the way that tax reliefs operate in the way that he describes would add very significant cost. However, we do, of course, keep all taxes under review.