I do not want to go any further than I already have this morning. There will be a wider review of corporation tax and how we go forward on this area. With the treatment of debt, there are particular issues with financial services companies and groups containing them that mean that we need to look at the issue carefully. I note the hon. Gentleman’s comments and we will take them into account.

The hon. Gentleman asked about the retrospective nature of the legislation. The original commencement date of the debt cap legislation was 1 January 2010. The regulations are made under the regulation-making power contained in that legislation, and so have the same commencement date as the primary legislation. That provides certainty and reduces the need for transitional arrangements. Because some of the legislative changes were announced in November 2009, there was an expectation that the rules would apply from 1 January 2010. To ensure that that does not add unfairly to the compliance burdens of groups, there is an opportunity to elect that those parts of the debt cap rules affected by the regulations do not apply until the regulations are laid.

The hon. Gentleman asked about the regulatory burdens more generally, and whether businesses and HMRC would have additional costs as a consequence of the changes. The cost of the changes in the debt cap legislation are negligible for both businesses and HMRC, which reflects the fact that the proposed changes do not fundamentally alter the operation of the debt cap rules, but ensure that they operate in the way originally intended. Most of the changes do not make a difference at all to the costs for groups, while others provide a small saving, such as the exclusion of securitisation companies from the debt cap and the changes to partnership costs.

The hon. Gentleman raised the issue of the debt cap working group. It will meet before the end of the year to continue discussions. It is made up of tax professionals and representatives from business, including the big four accountancy firms, major commercial law firms and the CBI. He also asked about further areas of improvement and highlighted concerns raised by Deloitte. HMRC will continue to work with Deloitte and other representatives, via the debt cap working group, to identify concerns and solutions.

The hon. Gentleman asked about industrial and provident societies. There is a question of why payments by industrial and provident societies are not already treated as interest under a loan relationship. There is a special rule for industrial and provident societies that treats the payments that they make to shareholders as  interest under a loan relationship, whether or not those payments are legally interest. That means that, for an industrial and provident society, dividends and bonuses paid to shareholders are treated as interest. A company’s relationship with its shareholder is not one of borrower and lender, and so it is not correct that such payments are included as financing expense or income in the debt cap calculations of the company, and hence the changes contained within the schedule. I hope that that is a helpful summary of the contents of not only Clause 11, but schedule 5.