The Minister and I will no doubt disagree on many occasions about the GAAR. Today is one such occasion, although its application to the Bill,  such as it is, is uncontroversial. The problem that we have with the general anti-abuse rule as it stands is that it is so narrowly defined that the number of occasions on which it will be used will be few and far between. A question therefore arises of the extent to which it will prevent the kind of abuse that has caused the public such outrage in recent months. The rule requires the agreement of a panel of experts, all of whom are drawn from the tax avoidance industry, before it can be used by HMRC, and that consent is not unlikely in most cases.