I will perhaps be more generous to the Minister than the hon. Member for Rayleigh because my view is that the explanatory notes were clear that there was never any intention to introduce a new spectrum of subjectivity to how penalties would be applied. However, genuine concerns were expressed by the various representative bodies that contacted the Minister about how the law would be interpreted. There was a real fear that we would see the introduction of a more subjective test to whether penalties would apply, rather than an objective one. I will not raise everything from the debate on the Floor of the House, which was not in relation to the schedule but to earlier clauses that also used the word “think”.

Essentially, by withdrawing the phrase “HMRC think”, the Government’s amendments achieve the same result as my amendments, which try to introduce a more objective sense to the use of particular language. That is clearly an improvement and allows the representative bodies to welcome the rationalisation more broadly than they were initially able to.

In addition to the points made by the hon. Member for Rayleigh, I would appreciate the Minister clarifying the following matter. I notice from the Minister’s letter that the meaning and effect of the schedule will not be changed by the amendments. If the intention was, as I am assuming, to try and make the legislation more straightforward, what impact has the little exchange between representative organisations had on the drafting of future legislation? We know from the Financial Secretary’s letter to the Committee on 22 May that

“‘think’ is used in over 3,000 instances in other statutes, including in Finance Bills”.

Will there be a policy change from now on? Are we going to see HMRC officers, or anyone else, “thinking” about future Finance Bills and other legislation?