Transfer of Tribunal Functions and Revenue and Customs Appeals Order 2009

My Lords, I apologise for intervening, but I should like to clarify what I was saying. I was not talking about the principle; we recognise that it is a sensible mechanism. However, there is a great lack of specificity in what the taxpayer can expect from a review. The Minister read out what is already available in the Explanatory Memorandum, but responses from the professional bodies focus much more on the purpose of the review, precisely what the procedures are that the taxpayer can expect at any point in time, and other matters. The order allows HMRC—I paraphrase—““to make it up as they go along”” and gives very little information that taxpayers can hang on to about the order. For example, what is the nature of a reviewer? Is a reviewer genuinely independent of the decision-maker? Is it a different person who did not make the decision? Many things worry the professional bodies which, with respect, the Minister has not dealt with.