I understand that point and the hon. Gentleman might understand it as well. We are, I hope, both individuals who take a common-sense view of such things. Unfortunately, that is often not what the courts do when looking at the technical definitions that we enshrine within our statute. The Institute of Chartered Accountants has highlighted a perceived risk, which is not necessarily born from my own line-by-line scrutiny of the Bill. It suggests that if we append the notion of entering into contracts to the activity of a group company that is essentially a shell parent arrangement, that might well be an imprecise definition of what that parent company actually undertakes. Such an approach might not capture the true spirit of the Bill, which is something on which he and I agree. Consequently, requiring the company to have a permanent establishment through which the business is carried out—indeed, maintaining the existing definition of to “enter into contracts”—could be seen to run counter to commercial realities. If existing practice in law is based on the term “do business”, and if that has worked successfully since the Finance Act 2003, it might be more prudent to retain that wording.

As I said, the point is specific, but I wanted to draw out the Minister’s definition, not least because courts will look at what Ministers say for guidance should any cases crop up in the future.