As the hon. Gentleman will be aware from reading the review, it is a very thorough and comprehensive piece of work and Sir Amyas goes into this question. He has accepted the case for a loan charge in principle—he recognises that it was important to address the issue of abusive tax avoidance—but he said that it should apply to loans taken out after a specific date. In his judgment, that represents a fair balance between the concerns that the hon. Gentleman raises and the loan charge, and the Government have accepted that.