I do not profess to be a taxation expert, but, like many members of the Committee, I received a brief this morning from the Chartered Institute of Taxation highlighting its concern about the application of the new rules for distribution in specie, not in cash. The brief provides a number of examples that demonstrate how the Bill is insufficiently clear. Unless the Minister wants me to bore him to death by reading out the examples—[ Interruption. ] I shall read them out if he wants me to—[Hon. Members: “One or two.”] I shall read out all three. The first example states:

“A ‘dividend’ is declared in a specified amount, which is then satisfied by the issue of a loan note or similar instrument. In such a case it seems that there is a ‘distribution out of assets’ for the purposes of paragraph B of section 1000 but there is no ‘transfer’ within the meaning of section 1002(2), in which case section 1002(3) does not apply to disapply paragraph B. Clearly at a later time the loan note will be settled but this will be a separate transaction and should not affect this analysis.”

The second example states:

“A ‘dividend’ is declared in a specified amount, which is then satisfied by an entry in an inter-company account. Again, as for 1, it seems that there is a ‘distribution out of assets’ but there is no ‘transfer’ of an asset.”

The third example—I promise that this is the final one—states:

“A ‘dividend’ is declared in the specified amount, which is satisfied by the transfer of an asset already held by the company. This may be a financial asset such as a receivable issued to it at an earlier time by a group company, shares or land and buildings. Again there will be a 'distribution out of assets' but in this case there will also be a 'transfer'. In this case we assume that the legislation can be applied on that basis that because the amount was declared as a cash amount then it is regarded as a transfer of cash for the purpose of (amended) section 1002(2)(a) and so again section 1002(3) does not apply to disapply paragraph B.”

The institute goes on to say:

“We would welcome confirmation that our interpretation is correct.”

It also says:

“These three situations contrast with the probably much less common situation where a ‘dividend’ is declared of an asset”.

If the Minister can give a response to that, he definitely has my admiration.