Jane
Kennedy: I have not seen that article, although I looked
at the Financial Times today. I am aware of the concerns that
have been expressed, but I am also aware
from my informal discussions with representatives of the City of London
and so on, that there is now a great deal less anxiety than there was
when we first introduced the detailed draft clauses for consideration
in January. I will look at the article and the
report. I
should like to comment briefly on the question of fees paid by offshore
trusts and whether they should count as a remittance. If the fees paid
were exempt, it would be possible for UK residents to fund their UK
lifestyles, such as school fees, medical fees—I hesitate to say
nanny’s fees—which non-remittance basis users patently
could not. I believe that that is an unfair outcome, but neither would
it make any clear contribution to competitiveness, which the Government
amendments
do.
Mr.
Hoban: I just wanted to touch on the issue of fees. My
amendment, which leads the group, says that because the services of the
driver, the nanny, the cook or the butler happen to be undertaken and
enjoyed in the UK, they would still be covered by the remittance rules.
However, where services are enjoyed offshore, for example if a trust
managing UK-based investments is based offshore, they will not be
covered. Services enjoyed in the UK would be caught, but not the
investment fees charged to an overseas trust. We may have a longer
debate on that
later. 1.30
pm
Jane
Kennedy: I would rather do that later, and it is likely
that we
will. Our
changes in response to representations make the remittance basis more
sustainable. Following consultation, we have made some changes. For
example, we have introduced certain exemptions for existing funds.
Those set up before 6 April will continue to be able to invest tax free
with their existing funds, as long as the individual does not provide
further
funds. The
argument about the definition of “relevant person” is
interesting. The relevant person rule prevents a significant amount of
tax avoidance, whereby people could simply give something to another
individual to import. Stopping that abuse was always going to be
unpopular, but we had to strike a balance. We have got the balance
right by focusing the rules on close individuals and immediate family,
rather than using the much wider definition that we originally
proposed. The inclusion of a minor grandchild as a relevant person
follows broadly the same approach as that used to determine whether a
non-resident trust is settlor-interested, except that the non-resident
trust rules also include adult grandchildren. Individuals giving
unremitted money or assets offshore to a relevant person would need to
make arrangements with that person, to enable them to keep track of any
remittances to the UK. I acknowledge that there is complexity there for
the
taxpayer. Amendment
No. 374 would cut across the Government’s amendments in this
area by changing the ordering rule within the mixed-fund rule. There
are various ways in which the mixed-fund rule could be ordered, and the
way we have chosen again strikes a balance between fairness and
simplicity. The ordering treats employment income as arising first and
is therefore favourable to the taxpayer, as the hon. Member for Fareham
suggests. That income has already been taxed and cannot be taxed again.
However, it discourages avoidance by making
untaxed income and gains come out next. Representative bodies obviously
would prefer the ordering rule to treat untaxed and already taxed
income and gains as remitted first, but that would prolong an
avoidance. Taxpayers still have the choice about whether they use a
mixed fund. If they do not, the rule does not
apply. Mr.
Hoban: Well-advised taxpayers—the sort of people
who might seek to use the rules for avoidance—would tend not to
have mixed funds. I am particularly concerned that those people who are
not represented, who know what the previous rules were, would find it
potentially more difficult to comply with these rules. Changing the
ordering may make it more difficult for the unrepresented taxpayer to
comply.
Jane
Kennedy: The hon. Gentleman makes a fair point. My
understanding is that the vast majority of those using the funds would
not be in that position; they would be getting good advice. However, I
would want to consider whether his point is
valid. I
understand the purpose of amendment No. 495, and would like to assure
hon. Members that the exemption in new section 809S applies to untaxed
foreign employment income as it does to other untaxed foreign income,
because of the provisions in new section 809J(1). I knew that it was
not a yes or no answer. As long as the payment is made directly to
HMRC, it will not be treated as taxable remittance. The hon.
Gentleman’s amendment is technically deficient as it would be
made to the accrued income scheme provisions. However, I realise that
the legislation on that point might justifiably be described as a
little unclear. I am grateful to the hon. Gentleman for his suggestion,
but if he will withdraw his amendment, I shall give serious
consideration to whether an amendment on Report would bring the desired
clarity to this
point. I
shall make one or two final points. The ordering rule, on which he
pressed me earlier, applies to funds remitted to the UK and so it is
irrelevant whether funds have gone elsewhere—as long as it is
not within the UK. On amendment No. 468, I do not really understand why
he believes that there is a problem with how people are supposed to
self-assess. If he has examples of where that might be a problem, he
can write to me and I would be happy to give that some detailed
consideration and reply to him in relation to a more specific
case. Finally,
the hon. Member for Hammersmith and Fulham drew my attention to the
article in the Financial Times, and I know that others have seen
both that article and the report. However, on the survey, I shall
simply say that a survey by Barclays Wealth states that the residence
and domicile tax changes as they now stand, have not led to non-doms
leaving the UK—that has not come from Government sources but
from independent sources. The report to which he is referring states
that the UK remains the most attractive place in the world for
non-domiciles. I hope that he will accept that reassurance. We are
conscious of the concerns in the business community about the changes
that we have proposed. I believe that our response has been measured
and responsible and I hope that the Committee will acknowledge
that.
Mr.
Hoban: Although I do not wish to trade reports with the
Minister, having read the press coverage of the Barclays report, my
recollection was that one of the
reasons for non-doms not leaving the UK was the difficulty they were
having selling houses in this troubled housing market. We understand
the issues, but we are concerned that there is still a lack of clarity
on some of the measures and that some work will have to be done to
produce guidance to help taxpayers achieve their
goals.
Jane
Kennedy: I do not wish to prolong the debate, but on the
point about clarity, will he accept that the remittance basis remains a
complex area. We have gone a long way to try to help clarify that, but
there will still be many instances where people with complex
arrangements will probably need a lot of professional advice on how
they manage their
affairs.
Mr.
Hoban: I am sure that outside advisers will be delighted
to hear that people using remittance basis will continue to need to use
their services—they will be reassured about that. I might touch
on some of these issues in the next group of amendments, but I suspect
that there is more work to be done in this area and that some of the
matters relating to the way in which this debate has developed in
recent months do give rise to some problems. I am grateful to the
Minister for agreeing to look into amendment No. 495 and how that might
be dealt
with. On
amendment No. 365, although the Minister prays in aid precedents from
trust legislation, I still believe that we are in danger of potentially
creating quite a difficult regime for people to comply with. Although
the wealthier end of the non-dom market might be able to find advice
and put structures in place to ensure that their adult children report
to them gifts or transfers that they have made to grandchildren, the
legislation captures so many people that some taxpayers will
inadvertently be caught in this net—through no fault of their
own, but because of the complexity of the rules. It would be better to
have a more restricted definition of relevant persons. I am
disappointed that the Minister has not moved on that. However, I beg to
ask leave to withdraw the amendment.
Amendment,
by leave,
withdrawn. Amendments
made: No. 482, in schedule 7, page 157, line 39, at end
insert— ‘(9A) The cases in
which income or chargeable gains are used in respect of a debt include
cases where income or chargeable gains are used to pay interest on the
debt.’. No.
483, in schedule 7, page 158, line 12, leave out ‘settlor
or’. No.
463, in schedule 7, page 163, leave out lines 20 to 23 and
insert— ‘(2) If property
which derives (wholly or in part, and directly or indirectly) from an
individual’s income or gains within a relevant paragraph (and
for a tax year) is transferred to a mixed fund, treat the transfer as
consisting of or containing the income or
gains.’. No.
464, in schedule 7, page 163, line 25, leave out ‘has
been’ and insert
‘is’. No.
484, in schedule 7, page 163, line 26, leave out
‘capital’ and insert
‘gains’. No.
485, in schedule 7, page 163, line 29, leave out
‘capital’ and insert
‘gains’. No.
465, in schedule 7, page 163, line 30, leave out from
‘treat’ to end of line 31 and insert
‘the income or gains as transferred to the
fund. (3A) Treat an offshore
transfer from a mixed fund as containing the appropriate proportion of
each kind of income or capital in the fund immediately before the
transfer. “The
appropriate proportion” means the amount (or market value) of
the transfer divided by the market value of the mixed fund immediately
before the
transfer.’. No.
466, in schedule 7, page 163, line 33, leave out ‘(d)’
and insert
‘(h)’. No.
467, in schedule 7, page 163, line 33, at end
insert— ‘(4A) A transfer
from a mixed fund is an “offshore transfer” for the
purposes of subsection (3A) if and to the extent that section 809P does
not apply in relation to
it. (4B) Treat a transfer from
a mixed fund as an “offshore transfer” (and section 809P
as not applying in relation to it, if it otherwise would do) if and to
the extent that, at the end of a tax year in which it is
made— (a) section 809P
does not apply in relation to it,
and (b) on the basis of the
best estimate that can reasonably be made at that time, section 809P
will not apply in relation to
it.’. No.
468, in schedule 7, page 163, line 38, at end
insert— ‘809QA Section 809P:
anti-avoidance (1) This section
applies if, by reason of an arrangement the main purpose (or one of the
main purposes) of which is to secure an income tax advantage or capital
gains tax advantage, a mixed fund would otherwise be regarded as
containing income or capital within any of paragraphs (f) to (i) of
section 809P(4). (2) Treat the
mixed fund as containing so much (if any) of the income or capital as
is just and reasonable. (3)
“Arrangement” includes any scheme, understanding,
transaction or series or transactions (whether or not
enforceable). (4)
“Income tax advantage” has the meaning given by section
683. (5) “Capital gains
tax advantage”
means— (a) a relief from
capital gains tax or increased relief from capital gains
tax, (b) a repayment of capital
gains tax or increased repayment of capital gains
tax, (c) the avoidance or
reduction of a charge to capital gains tax or an assessment to capital
gains tax, or (d) the
avoidance of a possible assessment to capital gains
tax.’.—[Jane
Kennedy.]
Mr.
Hoban: I beg to move amendment No. 375, in schedule 7,
page 164, line 2, at end
insert— ‘(3) This section
shall not have effect with respect to gains accruing to an individual
on the disposal of an asset if the disposal took place prior to 6 April
2008.’.
The
Chairman: With this it will be convenient to discuss the
following amendments:
No. 399, in
schedule 7, page 184, line 37, leave out ‘2008’ and
insert
‘2009’. No.
400, in schedule 7, page 184, line 39, leave out
‘2008-09’ and insert
‘2009-10’. No.
401, in schedule 7, page 184, line 39, at end insert
‘, except for the amendment made by
paragraph 1 to insert a new section 809G in Part 14 of ITA 2007, which
has effect for the tax year 2008-09 and subsequent tax
years.’.
Mr.
Hoban: There is one issue that I want to raise under
amendment No. 375; and then, under amendments Nos. 399 to 401, I shall
deal with some broader concerns about the handling of the
legislation.
On amendment
No. 375, the accepted position prior to 6 April 2008, where a
foreign-domiciled individual gifted foreign-sited assets, was that once
the deemed gain was realised, it could not be remitted, as the gain was
not represented by any money or money’s worth in the hands of
the individual making the gift. Accordingly, provided that there was a
genuine gift, with the donee—who could be the trustee of an
offshore settlor-interested trust—assuming full and unfettered
control of the property gifted, the gain arising on the making of the
gift could never be accessible. The HMRC capital gains tax manual, at
CG25331, sets out the position as
follows: “Where
an individual assessable on the remittance basis has gifted foreign
assets to another person and has not received any disposal proceeds he
or she may still be deemed to have realised a gain on the disposal. As
that gain is not represented by any money or moneys worth in the hands
of the individual making the gift, it is not possible for the
individual to remit the gain. The gain arising on the making of the
gift can therefore never become
assessable.” That
is, I think, a clear statement of where practice prior to 6 April 2008
led
people. The
new section 809R set out in schedule 7 creates some uncertainty in the
minds of advisers as to meaning. The optimistic, preferred best
interpretation is that new section 809R does not apply in relation to
gains that arose prior to 6 April 2008. It is understood that that is
also the view of HMRC. Accordingly, the old legislation states that,
provided that there was a genuine gift, there would be no tax liability
on the gain that arose when the gift was made. While it has been
helpful for HMRC to have made its view known, doubt and concern still
remain. 1.45
pm The
potential sums will often be significant, and it is likely that
inadequate records will have been kept to establish the position since,
at the time, the law was clear that there could never be a tax charge
as a result of the gift. Accordingly, taxpayers who made gifts of
foreign assets offshore prior to 6 April 2008 will be concerned by the
split in opinion; some suggest that new section 809R could exist
retrospectively. Taxpayers who made absolute unfettered gifts of
foreign assets offshore prior to 6 April 2008 had a legitimate
expectation that the gain deemed to have been realised on the making of
the gift would never come into charge. The new legislation should be
clear, which is why amendment No. 375 seeks to
insert: “This
section shall not have effect with respect to gains accruing to an
individual on the disposal of an asset if the disposal took place prior
to 6 April
2008.” That
makes the position clear so it is beyond doubt that new section 809R is
not meant to have a retrospective impact. Advisers would be grateful
for that conformation, and would perhaps be even more
grateful—as would I—if the Minister felt obliged to
accept the amendment, but when she hears what I am about to say next,
she probably will not.
I am
concerned about the process that we have gone through to get to this
point, which is why amendments Nos. 399 to 401 seek to defer the
commencement of major parts of the schedule to the start of the 2009-10
tax year, with one exception. Assuming that my drafting is correct, the
amendments do not seek to defer the £30,000 charge. We have
different views about the amount
of and the timing of the charge. Although we do not believe that it
should be deferred, the complex rules surrounding the changes should
be. Today’s debate is proof of why deferral of commencement is
important. Last
Thursday night the Government tabled, I think, 90 amendments to the
schedule, in addition to several earlier batches of amendments. Can the
Minister tell the Committee how many amendments have been tabled to
schedule 7 and whether that is a record number of amendments to a
schedule in a Finance Bill? The volume of amendments is indicative of
two things: first, the willingness to listen to the concerns raised by
representative bodies during this process, and I give credit for that;
and secondly, the state of the legislation when it was first published
a couple of months ago. I suspect—I think that the Minister may
have confirmed it this morning—that this is not the end of the
amendments to the schedule and that we will see more tabled on
Report.
The overall
volume of amendments tabled is, in a way, reflected in the volume of
amendments that I have tabled to the schedule. It reflects how the
changes to very complex areas of taxation have been dealt with in a
tight time scale. In October, the Chancellor announced a series of
measures in the pre-Budget report: on the charge, the denial of
allowances, changes to day-counting rules and on addressing anomalies
in the rules on remittances. He promised consultation, and a document
was published on 6 December 2007—just four months before the
rules were to come into effect. Draft legislation was published on 18
January, which triggered much of the outcry about the
Government’s intentions. John Cullinane of the Chartered
Institute of Taxation
said: “but
one of the unfortunate things is the way in which these proposals came
in unannounced, caused brouhaha, and then were subject to a lot of
compromises and have generally gone off at half cock. The result of all
that is that any kind of genuine, rational, consultative look at the
whole thing, to see how we can best give effect to this principle, that
the greater your connection with the UK the more of a burden you should
bear, has just been ruled out and we have a very complicated regime
with as many anomalies as
before”. Those
are quite harsh words from someone who is known to be measured in his
comments about Government tax
policy. Malcolm
Gammie from the Institute for Fiscal Studies said that the draft
legislation “apparently
went very much further and had a very much greater impact than had
generally been
anticipated”. He
summarised the problem as
follows: “I
think that really the general uncertainty it generated as to what
precisely the rules were going to be, how wide-ranging they were going
to be, really led to the degree of outcry that there was and the
publicity it
obtained”. I
think that that is a fair statement. The volume of comment in the
aftermath of the publication of those draft rules was significant, and
there was a sense that they went further than the Chancellor’s
original intentions. As a consequence of opposition from investment
managers, tax advisers and the art market, Dave Hartnett was forced to
publish a letter clarifying the changes on 12 February,
which was widely seen as yet another climbdown by the Government on
their tax policy.
In the
Budget, there were further concessions on assets to be remitted into
the UK and the applicability of the charge on children and spouses. The
de minimis
limit was increased from £1,000 to £2,000, as we discussed
earlier, and there were relaxations on CGT and offshore
mortgages. One might
have thought that that was a settled position and that after that the
consultation would be perfect, but from the moment the Bill was
published it was recognised that the content was incomplete. The
explanatory notes flagged that
up: “Some
of the clauses in the published version of the Finance Bill 2008 are
not wholly
complete.” That
is an understatement, given the volume and complexity of amendments
that have been tabled. The explanatory notes went further and stated
that there would be further discussions with interested parties, and
there was an open day for advisers at the beginning of this month. The
explanatory notes
stated: “Further
changes will be introduced by way of Government amendments during the
course of the
Bill.” That
is where we are today, discussing a long series of amendments that
arose from that process.
The
Institute of Chartered Accountants, when commenting on the schedule,
said: “We
are however concerned that a significant part of the legislation
remained unfinished even as it came into effect on 6 April
2008. We understand that this is to enable the final legislation to be
comprehensive and workable but are surprised that it was thought
appropriate to lay before Parliament legislation that is admitted to be
‘incomplete.’” The
way in which the changes have been made has also caused concern. Ian
Menzies-Conacher from the British Bankers Association summed it up very
well when he gave evidence to the House of Lords Committee on Economic
Affairs, saying that
“on balance it
would have been better to have deferred [the proposals] for a year to
allow a lot of the detailed problems that they are now seeing emerge to
be resolved properly...we are rapidly running out of time in the
present Finance
Bill.” Here
we are, debating those two hours before the Committee is scheduled to
adjourn. Some constructive discussions are taking place with officials
and problems have been addressed, but late in the process. There is a
great danger in drafting against rigid timetables, as we are almost as
likely to create new problems as we are to solve old ones—that
is the nature of drafting in a hurry. That concern was flagged up in
February when the Institute of Chartered Accountants
said: “HM
Treasury confirmed to us in a meeting in February 2008 that the
overwhelming message from the representations that they had received
had recommended deferring the more complex measures to enable workable
legislation to be
drafted.” When
the rules are finally determined, they will apply from 6 April 2008.
Yet no one knows what they are going to be, as they are subject to
further changes. This is an unreasonable situation for taxpayers. It
will lead to confusion as the rules settle down and could lead to
significant non-compliance in a system that is known for a very high
degree of compliance. Many taxpayers will be making remittances without
knowing their effect, which could turn out to be expensive if they make
the wrong choice.
If the
Government are not willing to postpone the changes until 6 April 2009,
an alternative would be to ensure that the rules apply only from the
date of Royal Assent and that remittances prior to that can be ignored.
This is hastily drafted legislation which people have had relatively
little time to digest, and there is concern that
even the amendments tabled by the Government in response to concerns
raised by tax advisers do not appear to address adequately all the
underlying
concerns. I
fear that, by the time we get to Royal Assent, some issues will be left
unresolved, and we will then be in a situation where we rely upon
guidance being generated. People will look to the “frequently
asked questions” section of the HMRC website for answers. There
is a lot of work to be done to enable taxpayers to comply with these
rules, and the Minister gave an indication of the type of work that
needs to be done during the earlier debate about de minimis
limits. No
one underestimates the amount of work that has taken place so far and
the amount that needs to be done going forward to make this work. We
are in a situation, a quarter of the way through the tax year in which
the Finance Bill gains Royal Assent, where there has been significant
uncertainty about how the rules will apply. The Government should step
back from this and understand some of the concerns they have created by
the way the legislation has been introduced. There are lessons to be
learned about how these changes should have been made. Consultation in
this area has apparently been going on since 2003, and there has been a
sudden acceleration and pick-up in pace since the pre-Budget report. I
am not quite sure what triggered that interest in amending these rules,
but clearly a lot of work has had to be done and is not entirely
finished. It is a lesson that we should all learn, on both sides of the
House, about how not to make tax
policy. Mr.
Mark Field (Cities of London and Westminster) (Con): My
hon. Friend the Member for Fareham is too polite to say that there has
been a little too much politics involved in some of these proposals.
While I accept that elements of this have been in play for five years
since the initial consultation process in 2003, breakneck speed has
apparently been required since October 2007 in order to get changes on
to the statute
book. As
I mentioned earlier, I have considerable sympathy with elements of what
the Government are trying to achieve. I represent a constituency that
contains the City of London, and have therefore heard some of the
somewhat hysterical response to changes regarding non-doms. Some of the
points raised are true, but other elements have been overplayed, not
least because there is a level of uncertainty, about which I will say
more
later. I
also represent a large residential population in some of the most
expensive real estate in the country, and it is a big concern, not only
in the City of London, Westminster and Greater London, but beyond, in
the home counties. There is real concern among people I speak to,
particularly those in their 50s and 60s, who worry about how on earth
their children are ever going to be able to have a quality of life akin
to the one that they themselves have been accustomed to, particularly
in relation to house prices. There is a sense that much of the concern
has been focused unduly and slightly unfairly on the non-dom community
as an extremely wealthy group, which is regarded as not paying its way.
There is an element of truth in that, and those of us in the political
world have to understand that that sense of inequality could be very
damaging to the country if it is allowed to persist for
long.
2
pm However,
a significant number of non-domiciled individuals who live and work in
this country do not earn huge amounts of money. Their voices have been
almost silenced in this debate because it has focused on
multi-millionaires. Their influence and the fact that they appear to
pay little in direct tax because of the arrangements that they are able
to work with HMRC are resented by an increasingly large number of
people—not just the usual suspects, but relatively
well-educated, middle-class, professional people who feel that they are
being priced out of the property market and private
schooling.
This matter
needs to be addressed. The Government sensibly began this process in
2003, but it should have been an ongoing process and not accelerated as
it has been in the past nine months. As my hon. Friend the Member for
Fareham has rightly pointed out, when the Bill gets Royal Assent and as
we approach the next Budget, we are still likely to have a whole range
of uncertainties as people are being taxed. The risk is that we end up
with the worst of all worlds and people will assume the worst rather
than consider what is actually happening.
I have some
sympathy with what the Government have tried to do. My party suggested
a sensible and relatively straightforward approach at the last Budget.
Rather than potentially open a can of worms by looking at the
arrangements for individuals overseas, we should have had a simple,
straightforward, one-off or annual charge for those with non-domiciled
status. I fear that politics have played too big a part in this issue.
I understand that we live in a political world, but we are,
unfortunately, also at a time in the economic cycle when these things
matter rather more than might have been the case two, three or four
years ago.
Many of the
changes have not been properly thought through. The real risk to the
Government’s credibility and, more importantly—dare I say
it—to the marketability of the UK across the world, is the sense
of uncertainty and almost incompetence that seems to be an everyday
part of the way in which the Government are addressing this issue. That
is regrettable. Representing the seat that I do, I can see both sides
of the argument. Time and again, I hear from people in the City who
say, “This is appalling; we are going to lose loads of
non-doms.” I do not think that there has been much evidence of
that happening yet, although my hon. Friend the Member for Fareham
might be right that the rather stagnant state of the property market
could be playing a part in that.
It is wrong
that we should be held to ransom by any group in society, such as the
very rich, or by any organisation. We need to get the balance right,
which means that we must think through the implications of this sort of
legislation. My hon. Friend has skilfully pointed out time and again
things that have not really been thought through. There will be a total
lack of certainty. We live in a world and have a global economy in
which labour has been at its most mobile in human history. We cannot
afford to lose some of the brightest and best people. Those affected
will not all be the richest individuals, although some inevitably will
be, and will make a contribution beyond paying tax. Some of the very
wealthy pay significant amounts of tax, such as council tax and VAT on
their purchases, and often
employ many people. The non-domiciled sector therefore brings a range of
benefits to our economy. That argument must be put forward if there is
to be a balanced approach, which the Government have slightly
lacked. I have made
some rather general points, and my hon. Friend has put his finger on
more specific points. I fear that we are putting in place an
ill-thought-through, rather uncertain framework, which will create the
worst of all worlds. It will probably raise relatively little money and
will dissuade people who would otherwise come to our shores from coming
here. One has to remember that there are 20 million people a year
emerging in the middle classes in India and China together. Those two
countries have 4 million graduates a year. We would hope to attract, if
only for a short period, some of the brightest and best of that talent.
The real risk is that we are perhaps putting in place an
ill-thought-through and uncertain programme on non-domiciles which will
dissuade those people from coming here. There are other options and
they might go to Singapore, New York or Dubai. Such places will seem
attractive in the short or even the medium term. That is our broadest
concern.
I hope that
the Government will give real thought to the timetabling. We can try to
put back the implementation of this so that there is a proper and
rigorous system that will stand the test of time. The worst of all
worlds would be for us to reassemble here next year and the year beyond
and have to rewrite many of these provisions, not least because of the
unworkability that may have been introduced. We will be advised by too
many tax advisers about the loopholes that should have been thought
through at the outset.
Thank you
for your indulgence, Sir Nicholas. I am sure that we will not have a
stand part debate. I hope that the Government and the Minister will
give us some assurances about exactly how see they this playing out in
the months and years
ahead.
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