James Wild
MP for North West Norfolk · Conservative · United Kingdom
“The Minister failed to respond to any of the questions asked by the shadow Minister, my hon. Friend the Member for Reigate (Rebecca Paul), so I will try again: some companies have expressed an interest in the business, so what discussions is the Minister, or his colleagues, having with potential buyers?”
“Passengers on the Fen line from King’s Lynn are suffering repeated cancellations and an unacceptably poor level of service. Now that the Government control both the track and the trains, will the Transport Secretary intervene and demand a robust action plan to sort out this poor performance?”
“The Hunstanton coastguard rescue officers I have met responded to 150 emergency shouts last year, and the small payment helped them to perform this role for locals and visitors alike.”
“Friend the Member for Keighley and Ilkley spoke about the offensive nature of those letters and their dreadful impact on victims—telling them that in September the first wave of criminals will be released. Others will not yet have been informed.”
“I completely agree with my hon. Friend. The Lady Chief Justice appeared before parliamentary Committees to tell MPs that she could have more sitting days if only the Government would produce, I think, about £20 million of funding—a fairly minimal amount in the scheme of the £1.3 trillion that the Government spend every year—rather than go…”
“It is a privilege to follow my hon. Friend the Member for Keighley and Ilkley (Robbie Moore), whose incredibly powerful speech gave voice to the victims and the impact that the horrific abuse has had on them. He has led on this issue consistently in this House, and his words should carry incredible weight.”
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Every one of 600 lines we hold for James Wild, in date order, each linked to its source. Free to read, in full, without an account. Page 5 of 12.
“I want to see them able to deal with the threat of illicit vapes in the same way as the metropolitan areas that benefit from the new formula that the Labour Government put in place. Clause 134 gives the Treasury wide discretion to make supplementary transitional regulations under the regime. In practice, it is a broad power to fill in the blanks. Can the Minister give some confidence that it will not lead to a complex, rapidly changing rulebook? The Minister referred to the parliamentary procedure for such regulations under clause 135. To be clear, those regulations include the ability to amend an Act of Parliament, which is a considerable power. If such measures came forward, it would clearly be right to properly consult and debate them before they took effect. Will the Minister commit to formal consultation in such cases?”
“Last year trading standards seized over a million illegal vapes inland and detained 1.2 million at ports in England. Those powers need to be properly resourced if they are going to be effective in stamping out illegal trade, as we know that trading standards is already under considerable pressure to deliver on its various legislative requirements. It is fair to say that there is patchy implementation across the country. What support will Government provide to local authorities to ensure consistent enforcement and genuine deterrence everywhere, not just in well-resourced areas? Counties, such as my county of Norfolk, have suffered as a result of the revised local government funding formula that the Government have put in place.”
“Can the Minister tell us when HMRC will make available a practical, user-friendly checking mechanism—whether that is a public database, an app or some other technology—so that retailers and consumers can verify stamps quickly and easily? What safeguards will exist to correct errors swiftly where inaccurate data risks unfairly damaging a compliant business? Clause 132 sets out a new information-sharing framework specific to the duty, letting HMRC exchange data with other bodies involved in enforcement. This is a legitimate and useful tool, but can the Minister give assurances about how the data will be logged, audited, and subject to clear internal controls? Clause 133 delegates day-to-day enforcement to local authorities and trading standards teams, which makes sense.”
“We come to the final group of provisions on the important issue of the new vaping duty. I speak to clauses 131 to 138, which concern the general provisions underpinning the new vaping products duty regime. Clause 131 authorises HMRC to publish information about stamped vaping products, for the purposes of enabling retailers, consumers and other persons to assess whether a duty stamp has been activated in respect of a duty product. That is clearly a sane, sound aim, which gives retailers a way to distinguish between legal stamped products and illicit ones. However, that will only work if the data HMRC publishes is accurate and accessible. Mislabelling would harm legitimate firms, and if the system is cumbersome it will put people off using it.”
“Under HMRC guidance, one VAT group member with an EORI number can make a customs declaration on behalf of another member. However, this group of clauses does not appear to allow for the formation of a CBAM group similar to a VAT or plastic packaging tax group. It is unclear how the measures affect those liable under the clause where one VAT group member uses another’s EORI number. If the current easement does not apply to CBAM goods, each member may need its own EORI number, which would add some complexity and administrative burden. Will the Minister clarify the position and understanding on that? If an issue needs to be addressed, will the Government introduce legislation to allow for CBAM grouping to maintain the existing simplifications, as I am sure is their intention?”
“Clause 143 places the liability for CBAM on the importer, broadly mirroring customs law by tying liability to the person in whose name the customs declaration is made, or on whose behalf it is made. That is intended to provide certainty, which is important, by aligning CBAM with established customs concepts and practices. Will HMRC give simple template wording or clear guidance so that businesses know how to declare who is responsible for CBAM and for sharing information throughout the supply chain? The Chartered Institute of Taxation has also raised an important question. As the Minister will know, some businesses operate within VAT groups. If they import goods, they hold an EORI—economic operators registration and identification—number, which anyone who lived through the Brexit negotiations and debates will be familiar with.”
“In Committee, I have repeatedly highlighted the importance of practical guidance: the hands-on support that HMRC will give to smaller and medium-sized importers —I suggest that the £50,000 limit is fairly low. Clause 142 ensures that where “a CBAM good has been declared for a special customs procedure,” processed into a non-CBAM good and then imported, CBAM is still charged on those emissions. This anti-avoidance provision aims to prevent companies from avoiding CBAM by doing limited processing to move a good out of the product list before releasing it into free circulation. The provision is welcome, as it would prevent people from dodging the rules.”
“Will there be a competitive disadvantage for high-carbon sectors left outside the first tranche, as they will still be exposed to cheaper, higher-emissions imports without any corresponding border adjustment? That point has been made to me privately by some of the Minister’s colleagues who would like to see a wider scope. Has the Treasury modelled how many businesses fall just above the £50,000 annual import threshold, and is it confident that it is capturing those that have substantial business and not imposing a burden on others? Clause 141 sets out when a good is treated as imported into the UK for CBAM. It covers standard imports and goods under special customs procedures, such as warehousing and movements between Great Britain, Northern Ireland and the Isle of Man. The clause intends to dovetail CBAM with existing customs laws.”
“Clause 139 establishes CBAM as the new UK tax on emissions, where a broadly equivalent price has not already been paid overseas. That is the foundation of the new charge. Clause 140 defines CBAM as “charged on the emissions embodied in a CBAM good” when it “is imported into the United Kingdom.” Those goods are defined by reference to the detailed tariff codes set out in schedule 15. Schedule 15 focuses on the initial regime for aluminium, cement, fertiliser, iron and steel products, and hydrogen, and it gives HMRC powers to keep the schedule updated in line with tariff changes. Could the Minister elaborate on why those five sectors were chosen for inclusion from 2027, and on when the Government will set out a clear timetable and test for extending CBAM to other sectors, such as glass or ceramics?”
“The Chartered Institute of Taxation, which has provided considerable help and input on all the provisions of the Bill, has flagged that further uncertainty will be caused by questions about the UK and EU emissions trading schemes being linked before the implementation date. The Government and the EU announced last May that they intend to link their ETSs, with mutual exemption from CBAM as part of the package, but I understand that formal negotiations have yet to begin. Perhaps the Minister can give us an update. There are also ongoing political discussions with the EU on the interaction of the two schemes, and the EU’s CBAM is undergoing some delays. That impacts on certainty for some transactions involving Northern Ireland, so I would be grateful if the Minister provided some clarity on where those discussions have got to.”
“A major concern is that the Government plan to apply a single sector-wide rate, based on average emissions, instead of differentiating by product type and country of origin, as I understand the EU scheme does. UK Steel, the Mineral Products Association and the Chemical Industries Association have warned that, without changes, the mechanism will leave domestic producers worse off than their overseas competitors and undermine planned investment and decarbonisation. Has the Minister modelled the impact of using a single sector-wide rate rather than a more granular approach, as well as the impact on investment, jobs and emissions in each of the covered industries?”
“This all lands on top of the other provisions within the Bill, namely the family farm and family business tax, as well as the cuts and delays we have seen in the sustainable farming incentive and the land management payment schemes and, of course, the additional pressures that are coming through in the cost of employment. Will the Minister set out what specific assessment the Treasury has made of the impact of CBAM on fertiliser prices, on different farm sectors and on UK food security? How does he intend to prevent downstream carbon leakage, which simply shifts emissions from factories to fields? Some industry groups, as recently reported in the Financial Times , warn that they think the Government’s current design has flaws and could accelerate de-industrialisation rather than prevent it.”
“Over time, both the EU and UK will raise the cost of high-carbon fertilisers, making lower-carbon alternatives more competitive as carbon prices tighten. Applying higher taxes where the UK is not a significant producer increases input costs for our British farmers. There is a risk of downstream leakage where UK farmers pay more for fertiliser due to CBAM, while competing with imported food from non-CBAM regimes that are still benefiting from cheaper, higher-carbon inputs, again undermining British producers and our food security.”
“As the Minister said, the new charge will initially apply to five sectors: aluminium, cement, fertilisers, hydrogen, and iron and steel. Fertilisers, which are one of the sectors brought within the scope of CBAM, are clearly a critical input for British agricultural producers, particularly for arable farms, where fertilisers already account for around 40% of crop-specific spending and around 12% of total farm costs. The National Farmers Union has warned about what it calls a fertiliser tax, and has said that using domestic production as the baseline for CBAM levies, despite the UK no longer producing ammonium nitrate at scale, risks a wholesale increase in fertiliser prices at a time when farm confidence, as we all know, is at rock bottom. The direction of travel is clear.”
“At the 2024 Budget, the Government confirmed the UK will introduce this new CBAM from January 2027, covering broadly the same types of highly traded carbon-intensive basic materials, and putting a carbon price on emissions embodied in certain imported goods, so that they face a comparable cost to that paid by domestic producers. Different countries clearly regulate industrial emissions to very different standards. UK manufacturers already have to follow obligations to measure, reduce and pay for their emissions, which are costs that we think need to be ameliorated. Extending that principle to imports should, in theory, help to prevent carbon leakage and ensure it results in real global emissions cuts, rather than simply offshoring production and pollution.”
“I am not clear from the Minister’s comments whether he has accepted the Valentine’s invitation, but I am sure I am not alone in not expecting a member of the Committee to corpse on CBAM, which some might say is a rather dry topic. While CBAM can play a role in ensuring a level playing field for UK manufacturers and producers, it also highlights the levies and taxes applied by the Government on energy, which means that our energy prices are much higher than our competitors. I think we all want to see that burden reduced.”
“We are sorry to see the Exchequer Secretary disappear. I hope that he comes back this afternoon for our further deliberations. The clause introduces schedule 16, providing for the administration and enforcement of CBAM. They hand responsibility for managing this new carbon import charge to HMRC, and set out detailed compliance rules, including registration, accounting periods, returns, assessments and appeals. The schedule runs to 27 pages of text. Under these measures, any business importing CBAM goods worth more than £50,000 in a 12-month period, or expecting to reach that threshold within 30 days, must register, report each quarter and keep detailed records potentially for up to six years. HMRC will have wide discretion to make “best judgment” assessments and to counteract any artificial separation of business activities.”
“I share the hon. Member’s concerns about the £50,000 threshold. Has he considered what might be a more appropriate level, in order to reduce the impact on smaller producers?”
“This is a broad delegated power that could have real implications for competitiveness, trade and treatment of foreign carbon prices. We have expressed concerns previously about the linkage with the EU ETS and the higher charges that might hit UK businesses as a result. I would be grateful for an update on where the negotiations have got to—if they have actually started—and how the Treasury will ensure that there is proper consultation and debate before using the powers.”
“Clause 152 sets out the interpretive rules for part 5 of the Bill, working alongside clause 151 and schedule 16 to ensure that terminology throughout CBAM is coherent. Clause 153 gives the Treasury the power to adjust CBAM if the UK’s emissions trading scheme is linked to another country’s carbon pricing system. The Minister touched on this briefly, but as I mentioned in the debate on an earlier group, in May the Government and the EU formally agreed to work towards linking their emissions trading systems to align carbon markets. I do not think the Exchequer Secretary responded to me on that point before he left the Committee. I am conscious that this is not the Minister’s portfolio, but can she give an update on where the EU-UK negotiations on the linkage have got to?”
“We come to the final group on the carbon border adjustment mechanism. Clause 150, along with schedule 18, makes the technical but critical changes needed to fit CBAM into the UK’s existing tax and enforcement framework. These measures ensure that the new tax uses the same information gathering powers, collection mechanisms and penalties already in place. It is sensible to integrate CBAM in this way without creating a new process. Clause 151 defines what we mean by “emissions” for CBAM purposes and firmly anchors the tax in the existing climate policy framework by adopting the definition in the Climate Change Act 2008. Greenhouse gas emissions will be measured in tonnes of carbon dioxide equivalent, which is sensible.”
“I am grateful to my hon. Friend for taking us through these detailed and complex clauses. On the point about lack of consultation, does he agree that there would be merit in holding public hearings ahead of a Finance Bill’s consideration in Committee, rather than just receiving written briefings? If we had done so, our Committee could have interrogated the concerns that my hon. Friend is so ably setting out.”
“One of the points that the Chartered Institute of Taxation also raised is the difficulty of dealing with promoters who are based outside the UK. It says that 20 to 30 of the active promoters who sell mass-marketed tax avoidance schemes have some offshore presence. How will the measures address the offshore issue? I am sure that the Minister will also address the 30-day point that my hon. Friend the Member for Wyre Forest raised.”
“Clause 165, which deals with the preliminary notice, allows a 30-day period in which to make representations to HMRC. Does my hon. Friend have sympathy with the view put forward by the Chartered Institute of Taxation, which says that that period is inadequate? A 90-day period is used for similar notices, such as follower notices or accelerated payment notices.”
“Is the Minister indicating that such people will be blocked from using the banking system in the UK if they are served with one of the notices? Where is that? I cannot see that in the clauses. Could those people simply ignore the notice and ignore any fines?”
“On the mechanics, the Association of Taxation Technicians has raised the point that the scheme is due to be a requirement from May, yet there is a lack of clarity about how or when advisers need to register. Further to that, will the Minister get HMRC to set target times for responding to—approving or rejecting—applications?”
“I beg to move amendment 50, in clause 259, page 236, line 4, at end insert— “(1A) After paragraph 5(8) insert— ‘(8A) A person is not liable to a penalty point as a result of the late filing of a return under this Schedule if they had no tax liability due in the relevant period. (8B) For the purpose of this section, “no tax liability due” has the meaning that the total amount of tax owed, after credit for any tax deducted at source, tax credits, or other reliefs, is zero or results in a repayment to the taxpayer.’” This amendment would mean that a person would not be subject to a penalty point because of the late filing of a return where there is no tax liability due.”
“It is good to be back in the saddle as we come on to some more clauses and, later this afternoon, new clauses. The amendment was tabled in my name, and I will speak to clauses 259 to 262 on penalties for the late filing of tax returns.”
“I am grateful to the Minister for her response and to the hon. Member for Maidenhead for highlighting the large number of people who miss the deadline. As I say, the reality is that a number of people get late filing penalties when they do not owe any tax. The case I cited was that of someone called Andrea, who suffered with mental health difficulties for many years. During that time, she never earned more than a few thousand pounds and was well below the personal allowance, so she never had any tax liability, but she ended up with £10,000-worth of late filing penalties. That is clearly not appropriate. The new system that the Government are bringing in could be strengthened with the principle that someone who does not owe any tax cannot get a fine. I therefore wish to press amendment 50. Question put, That the amendment be made.”
“These clauses represent useful steps towards greater tax certainty for investors, but I seek a little reassurance, particularly on the five-year extensions.”
“Will there be a right of appeal for developers who have previously been given certainty only for the advice to be changed? We do not want to undermine the certainty that is the whole purpose of this measure. Clause 268 provides that where the taxpayer withholds or misrepresents material facts, any clearance can be treated as invalid. That is clearly right in principle, but will there be guidance so that legitimate applicants are not deterred for fear of being second-guessed after the fact? Clause 270 will enable the Treasury to make regulations to amend part of the framework, including adding or removing tax matters on which HMRC can give clearances. It is important that there be consistency of approach, so will the Minister give a commitment that there will be proper consultation before any such changes are put into effect?”
“HMRC will be bound to maintain the treatment for five years, as the Minister referred to, and clause 265 will allow the period to be extended for a further five years. I cannot see a limit on the number of extensions that could be granted. Given that the purpose is to incentivise people to get on with investments and have certainty in advance of a project, will the Minister explain how multiple extensions could be appropriate, when that could appear to frustrate the ambition to get shovels in the ground? Clause 266 will allow HMRC to modify or revoke clearance if facts change or by agreement with the taxpayer. Flexibility is sensible, because clearly projects evolve. Will HMRC publish clear criteria setting out when, and on what grounds, it may modify a clearance?”
“In simple terms, a company planning a project on that scale can get specified advice on how the tax rules will apply and can get a written determination that both sides need to follow, subject to the caveats to which the Minister referred, including the change of law. Will the Government be keeping the £1 billion pound threshold under review? Will they commit to publishing clear statistics on the number of applications and approvals? Clause 264 sets out the binding nature of the clearances. Where HMRC issues a ruling and the facts remain consistent, it must apply that treatment so that the taxpayer can rely on it. That is what we need to see and what investors want to see: certainty.”
“Clauses 263 to 271, which introduce the new system of advance tax clearance, will give legislative effect to the commitment in the Government’s corporate tax road map to offer greater certainty for major investment. A public consultation was run last year; the summary of responses, which came out at the Budget, shows consistent support for this measure. We welcome it and look forward to it beginning in July 2026. Under clause 263, HMRC will be able to issue binding advance tax clearances for investments worth more than £1 billion over their lifetime. Although corporation tax is the most important area in which respondents argued for certainty, it could also cover VAT, stamp duty, land tax, income tax and other measures.”
“I will not detain the Committee long on these clauses. We support clause 274 and the sensible modernisation work, which—the Minister must have overlooked this, but I am sure he will acknowledge it in his reasonable way—began under the previous Government—”
“Not that one—the stamp duty one. Extending the oversight in clause 275 is clearly sensible, and I do not have anything to add on the cleaning-up operation in clause 277, the enabling of abbreviations in clause 278 or the title of the Bill.”
“The CBI said that the Government’s, “scattergun approach to tax risks leaving the economy stuck in neutral”. When we hear these siren voices, it is important that Ministers stop, listen and take account of the wider effects and headwinds that people are facing. That is why new clauses 35 and 33 are so important—they would require the Chancellor to come and account for the impact of her measures.”
“Small businesses are the backbone of our economy, with more than 5 million of them making up 99% of total business population. Together with small and medium-sized enterprises, they employ around 17 million people—shopkeepers, market traders, tradespeople and so on, as well as the entrepreneurs who are driving growth, creating jobs and trying to keep our high streets alive. Sadly, under this Government, they are facing increasingly high costs and burdens, and the Bill adds yet more. It is little wonder that the Federation of Small Businesses has warned of the perils of a continuing economic doom loop. Its small business index shows that confidence is at minus 71—the lowest level since the pandemic. It is minus 100 for hospitality firms, which the Exchequer Secretary will not be surprised about.”
“The Confederation of British Industry growth indicator—it comes from businesses, so I would not dismiss it out of hand—shows that firms expect output and headcount to fall. Businesses are closing as a direct consequence of the political choices that the Chancellor has made, many of which are set out in the Bill. The new clause would require that to be looked at, which is why it is so important; it would ensure that the Chancellor reviews and comes back to the House with proposals to use the tax system to support investment in growth. New clause 35 would require the Chancellor to publish, within 12 months of the Bill being passed, a full assessment of the Bill’s impact, particularly on small businesses, setting out the cumulative impact of measures in the context of wider pressures.”
“That seems to have disappeared, and little wonder: this Budget contained £26 billion of additional tax rises on top of the £40 billion in the first Budget, despite the Chancellor promising not to come back for more. Instead, the Government continue to drive the tax burden ever higher—to record levels. The new clause would require the Chancellor to look at the impact on businesses, including on increasing their profits and revenue. Let us look at the record of the Government: growth has flatlined; GDP grew by 0.1% in the three months up to November, having shown no growth at all in the period before; and inflation has been above the Bank of England’s target for the entirety of the last year. As a result, business confidence has collapsed.”
“We have heard a common theme in Committee that the Bill places yet more strain and burden on businesses already facing a difficult economic climate. It is stuffed full of tax increases: the family farm tax, the family business tax, the cutting of venture capital relief by a third, taxes on carried interest, taxes on taxis, and higher duties and environmental levies. I could go on at length, but I suspect I would not be hugely popular. The Minister—indeed, Ministers—may think that the measures are going to encourage growth. We have not heard much about growth in this sitting, except from Conservative Members. The Exchequer Secretary spoke a lot about the need to have balance in public spending, yin and yang, but he did not talk about growth, which used to be the central driving mission of this Government.”
“I will speak to new clauses 33 and 35 in my name and that of my right hon. Friend the Member for Central Devon (Sir Mel Stride) and my hon. Friend the Member for Wyre Forest. New clause 33 would require a review of the effects of the Bill on businesses: within 12 months of the Bill being passed, the Chancellor of the Exchequer would be required to conduct a full assessment of how its measures affect businesses across the United Kingdom. The Chancellor would then be required to report back to the House with recommendations specifically on how business taxes could be used to encourage greater investment of profits and revenues, and on how to give firms more certainty about the tax system. The Committee might well ask why the new clause is necessary. I will happily explain.”
“(2) The assessment under subsection (1) must consider how households at a range of different income levels are affected by the measures in this Act.”— (James Wild.) This new clause requires the Chancellor of the Exchequer to publish an assessment of the impact of the measures in this Act on the finances of households at a range of different income levels. Brought up, and read the First time.”
“Sadly, the Minister’s response is predictable; I think we have won the argument on why these measures would be useful have in the legislation, but we may not win a vote. The Minister refers to the TIINs once again, but as we have debated ad nauseum, they are forward looking, and not an after-the-event review of what has actually happened. That is the difference, which is why we keep returning to this. I beg to ask leave to withdraw the motion. Clause, by leave, withdrawn. New Clause 34 Review of impact of tax changes in this Act on households “(1) The Chancellor of the Exchequer must, within 12 months of this Act being passed, publish an assessment of the aggregate impact of the measures in this Act on household finances.”
“Whether through higher alcohol duty, air passenger duty or vehicle excise duty, or by making the cost of taxis more expensive, the measures in the Bill will directly hit households, and the costs that go on to business will obviously feed through into their prices as well. Behind all that, soaring borrowing means that billions of pounds are now being spent just to service the Chancellor’s debt. Hard-working families are paying the price for the failure to get a grip and to get growth into the economy. That is why we believe that the impact of these measures on households should be monitored carefully, and why the Chancellor should publish a full assessment, as new clause 34 would require.”
“The OBR has been up front about the reasons for that growth, if we can call it that: it says that slower real wage growth and rising taxes explain much of the decline. For a Budget that was supposed to focus on the cost of living, that is a pretty damning verdict. Even the Government’s own watchdog says that the Government’s measures will make things worse, not better. With inflation continuing to stay well above target and well above the level that this Government inherited, families are continuing to feel the price of this economic mismanagement, and they will do for some time.”
“I beg to move, That the clause be read a Second time. The new clause would require the Chancellor to publish an assessment of how the measures in the Bill affect the finances of households across different income levels. It would shine a light on the real impact on ordinary families of the Government’s choices. As we all know, households are under immense financial pressure, and the measures in the Bill will, in many respects, not make that easier. The Office for Budget Responsibility has confirmed that growth in real household disposable income per person is set to fall dramatically, from 3% in 2025 to just 0.25% a year over the forecast period. That is not just below the OBR’s March forecast, but well below the average growth of the last decade, as the Minister knows full well.”
“I am not sure about the analogy—I do not know whether the Minister was pulling that off the cuff. I do not think I heard him deny the figure that I quoted, which was that the OBR predicts that real household disposable income will increase by only 0.25% over the forecast period. I do not think that he is disagreeing with that figure, or that the average over the previous decade was growth of 1%.”
“(3) The Chancellor of the Exchequer must make a statement to the House of Commons on the findings of the report within three months of its publication.”— (James Wild.) This new clause would require the Chancellor of the Exchequer to review and report on the effects of the Act on the administrative burden on businesses, including the impact on SMEs and any mitigation measures. Brought up, and read the First time .”
“New Clause 36 Review of the effects of this Act on the administrative burden on businesses “(1) The Chancellor of the Exchequer must, within 12 months of the passing of this Act, lay before the House of Commons a report on the effects of the provisions of this Act on administrative burdens faced by businesses. (2) The report must in particular consider any— (a) change in the time or resources required by businesses to comply with obligations arising under this Act, (b) effects on small and medium-sized enterprises, and (c) measures taken by HMRC to mitigate any increase in administrative burdens.”