Thank you, Minister, for your statement, and I welcome the positive messages you've given us this afternoon and a suggested move on amendments. Llywydd, unfortunately, though, the Welsh Conservative group is not in a position to support the general principles of the Welsh tax Acts Bill, and so we'll be voting against both motions before the Senedd today.

When the Bill was introduced last year, I stated that I had some sympathy for the Minister—budgetary processes and taxation are of course very complex things, and this complexity has only increased during recent years. However, during the extensive consideration of this Bill, and I have been fortunate enough to sit on both committees, under the fantastic leadership of our two Chairs, it's become clear to me that the Bill as drafted poses some significant questions and challenges regarding the role of the Senedd in developing taxation legislation. As stated by the LJC committee, the Welsh Government's chosen approach

'is contrary to established parliamentary practice and principles associated with good law-making.'

The chartered institute of taxation stated that their

'starting point is that tax law should be set out in primary legislation', as it's subject to more scrutiny and debate than secondary legislation, as well as affording stakeholders the ability to properly be part of the scrutiny process in a more transparent manner. Yes, I understand that, at times, changes need to be brought forward quickly to respond to external events, but I don't believe that such a justification can be used to dilute the powers of the Senedd in determining tax policy.

The Minister has repeatedly emphasised the four tests contained within the Bill, which seek to constrain its provisions and how they are used by Ministers, but, during scrutiny, questions were raised about the appropriateness of some of these tests. For example, Dr Sara Closs-Davies suggested that the term 'tax avoidance' needed to be defined in the Bill as it has a wide definition that is problematic. Professor Emyr Lewis further stated that the drafting in relation to tax avoidance

'is much broader than simply a loophole-closing provision', highlighting that the provision, as well as for the purpose of responding to a court or tribunal decision, could be used to enact changes far wider than as stated by the Welsh Government. Professor Lewis highlighted that the purpose test as drafted could allow Ministers

'to achieve routine policy changes, significant or otherwise', including the potential to introduce a new rate of tax under purpose (c).

Meanwhile, the Institute of Chartered Accountants in England and Wales raised concerns about the powers within the Bill that allow Ministers to impose or extend a liability to a penalty under section 2(1)(b). They question what the power is

'going to do that's different to what we've already got in our primary legislation? It's not at all clear'.

Put simply, Llywydd, are we risking making a complex area of law even more murky and difficult to follow? The overarching theme, I sense, is that this Bill does need to be more limited, and I welcome suggestions for a sunset clause to be inserted into the Bill to allow for a more appropriate mechanism to be developed as well as a need for a statutory review of the regulation-making powers within this Bill.

There must also be more checks and balances in the use of the provision to change taxation law retrospectively, which goes against the key principle of certainty when developing such legislation. At the very least, any use of these retrospective powers needs to be given Senedd approval and is limited to no earlier than the effective date of the change to the predecessor tax.

To conclude, Llywydd, I believe that the Bill as drafted could open up a Pandora's box of unintended consequences for not just Welsh tax legislation, but for the supremacy of the Senedd in legislating more broadly. I believe and I know that the Minister is engaging constructively with the full suite of recommendations made by the LJC and the finance committees. It is important that if the Government really wants the support of the whole Senedd it works with Members of all sides to strengthen the Senedd's role in developing taxation law. Thank you.