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differently. Where a bank guarantee has been provided to the Inland Revenue Department, this will cover not only the amount of tax in dispute but also interest on it (at the rate applicable to judgment debts) until the case is determined. In cases where the Commissioner of Inland

Revenue makes an unconditional order, interest would again be payable if the appeal failed.

The discretionary exercise of the three options should go a long way towards discouraging misuse of the appeals system as a tax deferral device while leaving open an equitable route of appeal for genuine cases.

The present $3 billion of tax held over will gradually be reduced as the underlying appeals work through the system.

I congratulate Mr Brown and his colleagues in the Ad Hoc Group on the open-minded and very knowledgeable way in which they approached their task and the satisfactory solution that has now been reached. I am sorry that Mrs Fan is not in agreement, but unanimity in this complicated professional field is perhaps too much to expect.

Sir, I beg to move.