Certainly. By “gold-plating”, I mean that were we to agree to the amendments—I accept they are of a probing nature—we would be going further than the minimum requirement for meeting our EU obligations, by extending the measure to include link companies  outside the EEA. That would have a cost, which the hon. Lady specifically asked about. There is a potential cost of £5 million in tax arising from the discontinuing of litigation from earlier periods in three known cases, and there is potential for additional claims to be made. There are also likely to be consequences for HMRC’s position on wider group-relief EU litigation, with additional cost implications. So there would be a cost.

The hon. Lady raised the issue of UK group relief, and highlighted a case from 2000. The UK group relief rules were amended in 2006 to reflect the decision in the European Court of Justice on the Marks and Spencer case, which concerned group claims to group relief. The Government do not accept that that decision means that the consortium relief rules are non-compliant with EU law.

The rules relating to group and consortium claims are different, not least in that companies within a group are under common control, whereas a holding of only 5% can be sufficient to give entitlement to consortium relief. Therefore, we do not think that it follows that the analysis applied to group structures in the Marks and Spencer case also applies to consortium structures.

I may have said “£5 million” on the potential cost; I meant to say £50 million, so my apologies for that. I am sure that the hon. Lady is aware that a cost would be involved were we to accept the amendments. We do not think that they are necessary to comply with our EU obligations; we are successfully doing that as the Clause currently stands, and also minimising the cost to the UK Exchequer. For those reasons, I hope that she will withdraw the Amendment.