I have only minor points to make about the clause. Will the Minister explain the thinking behind the appeal being made only to the special commissioners? My hon. Friend the Member for Beaconsfield (Mr. Grieve) and I were thinking about that, and we considered whether to table an amendment to the clause that would offer a parallel way of appeal to the High Court. On balance, however, we decided that because some issues will undoubtedly require specific taxation expertise, the Government may be right to leave such matters with the special commissioners. I should be grateful if the Minister would say whether, during the drafting of the Bill, those who advise the Government went through the same thought process, because this part deals with the extension of existing powers and will give the director special extended powers.

Did the Government consider introducing a role for the High Court? At present they have not, but I wanted to flag up the issue because I can envisage that in another place, some Law Lords with specific expertise may think that there should be the option of a parallel appeal to the High Court, for the protection of the individual. If that were to be considered in another place, it would be helpful to have heard about the Government's thinking in Committee.