I have a brief question on the schedule. The Minister will know that in paragraph 4(3)(a) on page 355 of the Bill, the word “reasonably” is used in relation to the specified notice for such time. I am sure that the Minister is across the detail of that. What does he define as reasonable? A 90-day time limit is currently in place, but it is being removed and replaced with a time
“reasonably specified in the notice”.
Does he expect the limit to be maintained at 90 days, or will “reasonably specified” mean fewer or more than 90 days? If so, “reasonably” seems to give a lot of discretion to HMRC, and I would welcome clarification of what the Minister defines as reasonable.