My Lords, I am sure that the House will be glad that we have reached the last amendment at Third Reading. We debated different versions of the amendment in Grand Committee and on Report. On Report, the noble and learned Lord made some important statements in response to the issues raised by the amendment, which seeks a report on the integration of HMRC. In particular, we welcomed what the noble and learned Lord said on Report about the reports that would be made by HMRC in the first year or so of its operation.
The amendment before us today is different in two important respects from the one that we debated earlier. First, we have eliminated the reference to the Revenue and Customs Prosecutions Office that upset the noble and learned Lord on Report. I did not wish to upset him, so I removed the reference from this amendment. I am sure that the performance of the RCPO should be kept under review, but I am equally sure that another mechanism should be found.
The second respect in which the amendment differs is that it is drafted now to sweep up those matters that are not dealt with in other public documents. We believe that what the Minister said on Report about the content of the early reports by HMRC will go a long way towards meeting our concerns. But those reports may not adequately deal with all of the issues that are relevant to an assessment of the integration in terms of its costs, its benefits and its impact on taxpayers.
I have been particularly concerned that the reports will run out after about 18 months. Some of the issues that are relevant to how well the integration has worked will not become clear very early. In particular, the impact on tax yield would not be clear for some time, nor, almost certainly, would the impact on taxpayers, given the rather incremental approach to the way in which the operations of HMRC will change.
The noble and learned Lord may say, as he said on Report, that as time goes on the impact of the integration will be mixed up in some ways with other measures. I accept that, but it seems to me that it is a basic principle of good management that procedures should be put in place to differentiate the impact of different policies. If they are all to be muddled together, after a year or so no policy could ever be evaluated on an ex post basis. It is a principle of good government that policies are capable of being evaluated on an ex post basis.
That is particularly the case with the creation of HMRC. We have argued throughout the Bill that the policy was not well justified at the outset. We did not oppose the policy, but we made the point that the costs of integration were not well explained, the risks were not well identified and, in particular, the benefits in terms of increased yield were barely mentioned, let alone quantified.
So our concerns are that proper information is put routinely into the public domain, in particular after the first year, which is where the real test of the impact of integration can be determined. The amendment—because it focuses only on information that is not otherwise publicly available—could result in absolutely no additional information being put in the public domain. That would be splendid because it would mean that HMRC was doing a splendid job in being open and transparent about the effect of the integration. But just in case it does not do so, I beg to move.