My hon. Friend makes an important point. It is right that the Government are taking action to pierce the corporate veil and to levy an annual charge on properties that are held in certain corporate structures. They cite the purpose for such  action as trying to encourage the release of properties from corporate structures. I doubt whether owners of such properties would be so incentivised. They would probably be more incentivised to stay well and truly locked in corporate structures because they would not incur the charge. New properties will be subject to SDLT and if other properties come out of the corporate structures, they will be subject to the high level of SDLT so such action may have the opposite effect.

My hon. Friend asked why the provisions could not be applied to more properties. It is a fairly simple tax. People would clearly see its fairness, because it would ensure that those at the top of the property ladder passed down some of the benefit to help those who cannot even get on the property ladder. We all know people in that situation, and we want to find a way to help them.

Clearly, there have been disagreements within the Treasury—certainly within the Government. That is nothing new, but the measure is a welcome baby step towards a mansion tax. Obviously, it is our responsibility as the Opposition to challenge and scrutinise the detailed operational and technical approach that the Treasury is taking towards the tax. I have drawn attention to a few worries and have asked for more detail of how the tax will work in practice, and what revenue it will bring in. However, I have some additional questions for the Minister.

Regarding partnerships owning residential properties, the Chartered Institute of Taxation has commented on the enforceability of the annual tax on enveloped dwellings against a corporate member of a partnership. In January 2013, it commented:

“Although partners may be collectively entitled to all the assets of the partnership it is not entirely clear that…is effective in charging a corporate member of a partnership holding a high value dwelling”.

It referred to case law indicating that partners do not necessarily have an interest in that particular asset.

The institute also commented on the definition of partnerships in Clause 165, which is,

“where the partnership is entitled to a single-dwelling interest, this Part has effect as if the partners were jointly entitled to the interest (and the partnership had no entitlement to it).”

The institute said that that appears to override the case law position regarding partnerships with separate legal personalities that can hold assets in their own names, such as limited liability partnerships. It does not appear to address partnerships that do not have a separate legal personality.

The institute requested clarification of the policy intent of the charge on a corporate member of a partnership and whether the charge would be with reference to the corporate partner’s capital profit share or on the full value of the interest. Will the Minister clarify that all those concerns have been addressed?

There are a few other general points regarding the clause. How many £2 million-plus properties will be subject to the annual charge? What are the numbers of properties involved? Will the Minister provide a breakdown of the numbers of properties subject to each band? It is important for members of the Committee to see exactly which types of property are involved and where they fall in the various bands.