§ Income received in the United Kingdom from investments in British Possessions and Colonies shall be assessable to Income and Super-tax under this Act after the deduction of such Income Tax as has been paid in any British Possession or Colony upon such income.
§ Clause brought up, and read the first time.
§ Sir J. D. REES
I beg to move, "That the Clause be read a second time."
It is an unjust thing that income which has already paid Income Tax in one part of the British Empire should be assessed for further Income Tax at home. In case it should appear that this principle is a difficult one to urge upon the Chancellor of the Exchequer—whose attention I am not so fortunate as to enjoy, and which, perhaps, I do not deserve—I would point out that the principle of the deduction 380 in such cases has already been allowed by the Government in respect of Death Duties. The Death Duty payable to the Government of India in respect of Indian assets is deducted or allowed in assessing the Death Duties payable on the entire estate of the deceased person leaving assets located in India. This Clause extends that principle to Income tax and to other British Possessions. My submission is, that a principle which is allowed in regard to Death Duties should be equally allowed in regard to Income Tax. It is a hardship, when an income has paid Income Tax amounting to 2½ per cent. to the Government which affords the protection under which it is earned, that the same income should be subject to a tax of four times as much by the Home Government, to which it owes no protection commensurate to that of a Government, financially independent, under which the income is earned. I believe I should be careful here not to reiterate any of the arguments used in regard to the merits of Clause 5 of the 381 Bill. I would urge that not only should the Income Tax paid in a British Possession be deducted, but that the commissions paid to bankers and agents to recoup themselves for any services they offer, should also be deducted, with other necessary expenses. If the Chancellor of the Exchequer will not consider a proposition to make all those deductions, at any rate one might be allowed. I do not think I should be in order in urging that taxation like this, which deprives of capital a British possession greatly in need of capital, is in itself thoroughly bad, and should be resisted upon that score. On the present occasion it would be more immediately to the point to urge that such a deduction as I propose is called for by equity and justice. I do not know whether the claims of those who are affected by the provisions of the Finance Act in this respect appeal to the Chancellor of the Exchequer. I imagine I should not be justified in taking up the time of the House in pleading the way in which this affects the general financial position of a British possession. Perhaps I should be more in order in sticking closely to this immediate Clause.
§ Sir J. D. REES
That has nothing whatever to do with this. I think the hon. Baronet has misunderstood, but I do not know that the fact of one Member having misunderstood the point I was making would justify me in putting the whole House to the pains of hearing it all over again.
§ Sir J. SIMON
The hon. Gentleman has certainly explained his Amendment, but I am not quite certain whether his explanation is what I should have expected from the terms of the Amendment itself. If I understood him rightly, he was assuming this case: Supposing in some British Possession there is an Income Tax of 1s. 2d., and here the Income Tax is 1s. 3d., he suggests that it would be right to tax that income, so far as we were concerned, only by the amount of the difference, namely, 1d.
§ Sir J. D. REES
It would be fairer if the right hon. Gentleman were to say, suppose the Income Tax somewhere else were 2d., and here it is 2s. Then my point would be far clearer.
§ Sir J. SIMON
I am prepared to take either. I thought I had reproduced the illustration of the hon. Gentleman. Let me take his illustration. He is proposing, apparently, that the whole income should be taxed on the difference. Unfortunately that is not his Clause. The Clause has nothing in the world to do with that. It is a provision that we should first subtract out of the income that portion of the income which is used to pay the Income Tax elsewhere, and then that you should impose the British Tax at the full rate upon the difference, which is a different proposition. Either proposition is intelligible, but neither is the same as the other. Then there is this further consideration which I do not think the hon. Gentleman has had quite sufficiently in mind. He really is proposing to reverse what is the principle of Income Tax law. It is not the case, even about British Income Tax that you pay the tax on your income less the amount of the tax. That may be true of some other charges, but not about Income Tax. If a man has an income of £1,000 he has to pay Income Tax on the £1,000 and not on the £1,000 less some sum which will be sufficient to pay the tax on the smaller amount. Whether it be Income Tax or Super-tax the principle on which these things apply, he will see on consideration, is that you tax the amount of the income and not the amount that is left of the income after you have paid the tax. If that is true about the British tax, I cannot conceive why it should not be true about other taxes. The principle which is supposed to be at the bottom of the Clause is one which we could not accept in any case. If such a proposal was going to be made I doubt whether it could be fairly limited to British Possessions and Colonies. It is enough to say in general terms that the principle which we suggest should apply is a principle which is completely contradicted by the proposal which the hon. Gentleman makes, whether it is the proposal of the new Clause or the different proposal which I understood him to explain in his speech.
§ Mr. CHAMBERLAIN
I really do not think the answer which we have had from the right hon. Gentleman is adequate to the question which is raised by this Amendment. It is a question of serious concern to every portion of the Empire. I do not allege for a moment that the change which the right hon. Gentleman is making in the law at present raises this question 383 for the first time. It has been raised at more than one Colonial Conference, and it has been raised in communications from Colonial Governments to the Home Government on other occasions than those of the Colonial Conference. I do not, therefore, wish to be thought for a moment to allege that the change in the law proposed by the Chancellor of the Exchequer raises this very difficult and complicated question for the first time. But I think it still further complicates it, and I think it introduces new matter which it would be well for the House to consider at the outset. I am struck, with such experience as I have had of financial changes in this House, with the great difficulty which there is, once you have imposed a tax in a particular form, in subsequently alleviating its hardships or its burdens. We have had illustrations of it to-night. Take, for instance, the question as to the exclusion of an insurance to provide for the payment of Death Duties. My hon. and learned Friend (Mr. Butcher) was correct when he said that at the time when the tax was imposed and the Amendment was first moved in the Budget of Sir William Harcourt it was touch-and-go whether Sir William Harcourt would not accept it.
§ Mr. CHAMBERLAIN
I think at that time the difference would not have been very serious compared with the new-revenue which Sir William Harcourt was then raising. Perhaps I put it a little too strongly when I said it was touch-and-go, but at any rate Sir William Harcourt seriously hesitated before refusing to accept the Amendment. Now the Chancellor of the Exchequer says, "After all the years in which this has been in force you are asking me to make so great a sacrifice—in fact, to transfer so heavy a burden from shoulders which have become accustomed to bear it to other shoulders. That I cannot do." Therefore, I rather press that it is important to consider the bearing of these new taxes at the moment when they are imposed, and to try and make concessions at that moment, if we are going to make them at all, because it is at that moment when we make them most easily, and with the least sacrifice of revenue and the least disturbance of the financial arrangements of the Chancellor of the Exchequer. In return 384 for what do we pay taxes? In return for the security which we receive from the Government to which we pay them, and for all the benefits which we draw in any shape or form, and as an obligation which we owe as citizens of the country to the common weal and the common defence. The Chancellor of the Exchequer, rightly, under these circumstances, taxes all income which is brought home here and enjoyed here, and therefore is subject to his protection and the privileges which our law and our society and our nationality afford. The Chancellor of the Exchequer under this Budget goes one step further and attaches this taxation to income which is not brought home nor owned by someone who resides here. In the case of that income the possessor owes nothing specifically to the Government of this country in respect of that income which he does not bring home, which is not earned here, and which is not protected by the Government of this country. I am not arguing that the Chancellor of the Exchequer is wrong in doing so. That is quite a distinct question which I do not wish to raise. But I think the House will go with me so far as to say that the income which is earned in another country and remains in another country, under the protection of another country, is not in the same position as income which is earned in this country, or which is brought home to be enjoyed under the protection of this country.
It is not therefore quite sufficient to say, as the Attorney-General did, that we tax the whole income in the one case and that therefore we ought to tax the whole income in the other case. The circumstances of the two kinds of income and the services which the State accords to the citizens are quite different in the two cases. But that is not the whole of the argument. We are dealing in this Amendment with income earned in the Colonies. We are going to tax it in this country. The Colony also has an Income Tax. The double Income Tax is the subject of a difficulty which I, in my official career as Chancellor of the Exchequer had to consider with the Colonial authorities, and I think the right hon. Gentleman has had to consider it as well. I have felt that under the present fiscal relations of the Empire, we had no choice, and that we could not meet the Colonial demand. But the right hon. Gentleman is now proceeding farther in the matter on which the Colonies have already remonstrated. In the case of an 385 income earned in this country you charge on the full income, but is that parallel to what you are doing now on income earned in a Colony? If it is earned in a Colony, that Colony has its Income Tax, and the citizen only gets the income subject to that. You are going to tax this particular class of investment—not only the income which the investor possibly enjoys in this country, but also on the tax he has paid in another country. I do not complain of the system by which a man who earns £1,000 in this country is taxed on that income. But what you are saying here is that if he has an income in another country, where it is subject to the Income Tax of the Colony, even though he does not bring home the money, he is to be taxed here on that income. If you do that, ought you not to tax him on the income less the tax which he pays in the Colony? If he has lived in this country and brought the income home, you have taxed him on the income brought home. What you set out to do was to tax in the same way the man who does not bring the income home, but reinvests it in the colony. But you are going to tax him in a different way from the man who brought the money home. You are going to tax him on the money earned in the colony where it is subject to Income Tax.
It is rather a delicate question. I hope I have made my meaning clear. I think the House will see that the answer given was not a proper answer. There is a real distinction between Colonial income and Home income. There is a case for redress. I do not want to pledge myself to particular words, the effect of which only a lawyer or a draughtsman can exactly measure. What I wish to impress upon the Chancellor of the Exchequer is, that there is a case which he ought to meet, and that now is the time to meet it. When raising new revenue you can afford to give away a little part, but when the whole balance of the Budget depends upon the yield you are accustomed to expect, it is almost impossible for a Chancellor of the Exchequer, even when he realises what is being done, to right the wrong which is being committed. I urge this particular case with the more seriousness because I do feel that there is a danger in our Imperial relations in connection with this delicate question of taxation. I am anxious to say nothing which would make a case against the Imperial Government, or embarrass them in the presentation of the case which has to be met on behalf of 386 this country at any conference, or in any negotiations which may take place. But I do feel that we are on delicate ground, and I beg the Government to walk warily and to make such concessions as are reasonable to meet and to mitigate any sense of injury or any sense of irritation which may arise through our form of taxation.
§ Mr. LLOYD GEORGE
The right hon. Gentleman has referred to the difficulties with which every Chancellor of the Exchequer has been confronted for a good many years; I have no doubt that he received many deputations on the subject. I attended a Colonial Conference where there was a resolution proposed by one of the Colonial premiers upon this very topic. But I must say this, that when he looked into the matter of the difficulty from the point of view of the Imperial revenue and the loss which the proposal must necessarily inflict on the revenue, the resolution was withdrawn. I think they all felt that it was a position which we could not possibly redress without too great a loss to the revenue, in view of the amount which has to be expended on Imperial purposes. I recollect also receiving a deputation on the subject, and I must say that the case presented by the deputation was a very real one. This was the case put to me in regard to one particular Colony: A company promoted here for the development of the resources of that Colony. All the money was raised here, and spent there in developing that country. They pointed out that they had done a vast amount of admirable work in developing the resources of that country, and that still they were taxed, not only in respect of the ordinary income Tax, but taxed as absentees, which meant that they paid a sort of penal tax, while at home they paid the Income Tax of this country. I pointed out that that was more a grievance against the Colonial Government than against the Government at home. They said, "We have no redress against the Colony. But here we have got our votes and can bring pressure to bear upon the Chancellor of the Exchequer." I agreed, but on the whole I felt that justice was on our side and not on the side of the Colony. I felt that there was an injustice inflicted when all the money and all the directing brains were British, and it was of vast importance to the Colony to get the cash, that yet these people were penalised because they raised the money here.
387 Those are some of the difficulties with which every Chancellor is confronted when he comes to deal with the matter. It is not merely a matter of the amount of the revenue, but I think that there are equities on the side of the Imperial revenue. As the right hon. Gentleman knows, the same thing applies when you come to Death Duties. We have arrived at some sort of arrangement with the Colonies. I am not at all sure that that arrangement was not extended during the last few years. If a reciprocal arrangement were entered into with regard to the Income Tax, we would get nothing out of it. "Suppose," we said, "we excepted all our residents who have got investments there, and you do the same thing, we would got very little out of it." They saw that, and that it was not worth our while. The right hon. Gentleman has said that what makes it especially incumbent to give still more favourable consideration under this particular Budget is the fact that Clause 5 for the first time taxes incomes which are not brought over here. I think that on reflection the right hon. Gentleman will see that there is very little in that. The incomes enjoyed by men of moderate means are almost always brought over here and you are taxing those now.
§ Mr. CHAMBERLAIN
I think that that is not always so. I think that you will find a certain number of people who themselves have been settled in various Colonies who have up to this stage probably been in business, and who do not bring over their whole incomes, but reinvest a great part of it in developing the business, and they are wise to do it. They themselves have taken up an estate. They may come over here when the time comes to educate their children or something of that kind. I am not putting the case of a person resident in the Colonies, but that of a person who has been resident in the Colonies, and ceases to be resident there, and has come over here. Take the case of a man who has started an estate in British East Africa or Nigeria, where he is engaged in developing a considerable estate. He cannot develop it all at once. He takes from his income what he requires to live on, and the rest is invested in the development of that estate. That is at least one class of case which I think is entitled to the attention of the Chancellor of the Exchequer.
§ Mr. LLOYD GEORGE
I agree, but I may point out that Clause 5 does not apply to businesses. It applies only to stocks, shares, securities, and rents. That is not the case of rents, but of the development of a business, and therefore it does not apply there. I agree to that in cases where money is left to develop businesses, but I should say that there are comparatively few men of small means who can afford to roll up their investments and employ brokers in Canada, Australia, or elsewhere to reinvest their money. So practically, therefore, the only difference made now is that men who can afford to leave their money there have to pay. There is no difference in principle. It is only an extension of the class who are subject. Therefore I do not think that there is a case for making any alteration in this respect. Foreign countries are practically doing the same thing now. Take the present Income Tax in France. British residents have to pay their 1s. 2d., Is. 3d., or 1s. 4d. as the case may be there, and under the new Income Tax proposals they will have to pay the 1s., or whatever the Income Tax may be in France as well.
§ Mr. LLOYD GEORGE
No, but next year will arrive, and they will have to pay then. They will have to pay 2s. 3d. This has become not merely an international business, but an international business.
§ Mr. LLOYD GEORGE
I do not know. But I think that it is one of those questions which might very well be considered by the Committee which it is proposed to set up. It is one of those hardy annuals. There is a great deal to be said for the proposals in themselves on the merits, but, on the other hand, there is very serious objection to them, not merely on the score of revenue, but on the ground of justice. It is true that it is very hard to tax any man twice over for the same income. Then comes the question who is to give in. Are we to give in or are the Colonies to give in?
§ Mr. CHAMBERLAIN
The right hon. Gentleman sees that that is not the simple point raised by this Amendment. It is not the question whether you will tax a man twice over. It is a question whether you should tax him on his taxes.
§ Mr. LLOYD GEORGE
That was a question which was raised with regard to the Super-tax here. For instance, you Super-tax a man here on Income Tax which he pays. That is the contention. You raise almost the same questions. I should like the whole of these questions to be considered together. I think that it is a very proper subject for inquiry by the Committee. I do not know whether the hon. Gentleman will press it, but I undertake that the terms of reference will be so drawn that this will be considered by the Committee.
Mr. WILLIAM REDMOND
This is a matter on which I confess that I have some sympathy with the hon. Member who moved the Amendment, and it is a question which I myself brought before the House more than once. The Attorney-General, in his answer, did not seem quite to realise that this is considered to be a very serious question in nearly every one of the Over Seas Dominions. For instance, by a strange coincidence, in this very day's "Times," there is a cablegram which sets forth the protest of more than one of the Australian Governments on this point, and that surely is a matter to which the right hon. Gentleman should pay considerable attention. With regard to the new taxation, to which the right hon. Gentleman has referred, I do not propose to say anything—that is, the question of taxing incomes abroad which are not brought to this country. But I consider that the new Clause moved by the hon. Gentleman would, if adopted, meet a longstanding grievance of many of the self-governing Dominions. Take, for instance, a well-to-do Canadian, Australian, New Zealander, or South African, who desires to come home and is in a position to do so. He brings his income home to Europe, and spends it here, and it circulates for the benefit of this country to a great extent. He pays in the country from which he derives this money the Income Tax of that State, whatever it may be, and it varies in different Dominions. He pays also the absentee tax, because he is spending income elsewhere than in the country where he earned it. I do not say anything about the absentee tax; I think it is more or less equitable that where a man uses a country and enjoys its advantages, and spends the income he makes there for the benefit of other countries, he should pay the absentee tax. He pays the Income Tax and he pays the absentee tax, yet, because he spends his money here, he has to pay 390 the Chancellor of the Exchequer 1s. 4d. in the £ as well. I think myself that this really calls for serious consideration. It does not by any means encourage people to come to this country and circulate their money.
The right hon. Gentleman said that this was an international question, and that an Englishman going to Paris would be taxed on his income there, and would also have to pay the new French Income Tax. That remains to be seen. Personally, I doubt very much that the French Government will in future be so short-sighted as to compel any foreigner who brings money to Paris to pay the French Income Tax, while also taxing him on the money which he brings to spend in their country. I do not think that they will persist in that, though it is the case now. The French are very worldly-wise, and I do not think that they will continue to put a tax upon people who bring money to circulate in their country. There is a difference between the case of a foreign country and the case of one of the Dominions. [HON. MEMBERS: "Hear, hear!"] I know that hon. Gentlemen cheer that observation in a sense different from that in which I make it. My point is that there is a vast difference between a citizen of Canada, or Australia, or New Zealand, or South Africa who comes to Scotland, England, or Ireland, and the position of a man belonging to a different nationality, speaking a different tongue, and who is absolutely foreign in every way. If you are going to deny an abatement, or whatever you may be pleased to call it, to the Canadian, Australian, or New Zealander, who circulates his money here—if you are going to treat them in no way different from the way in which under present law an Englishman or foreigner would be treated in Paris with regard to Income Tax, you could not be surprised if, on opening your "Times" this morning, you found that the self-governing States and many Dominions are protesting. They say that they are willing to pay the Income Tax in the country to which they belong, but, if in addition to that they are willing and ready to pay the absentee tax, because they desire to travel abroad and come and live here for some years, if they are willing to come here and put their money into one of your banks, and spend it in Regent Street or Bond Street, or wherever it may be, and you charge them 1s. 4d. in the £, in addition to the taxes that they pay in their 391 own country, you cannot wonder if they complain and say that this is hardly the way to encourage them to come here. The right hon. Member for West Birmingham (Mr. Chamberlain) cannot say very much in the matter, because, unless I am very much mistaken, this question has been brought every year, certainly for the thirty years I have been in this House, before each Chancellor of the Exchequer, and not one of them, not even the ex-Chancellor of the Exchequer who is here, ever did anything to meet this particular grievance; and in all the talk we have heard, especially on this side of the House, about Imperialism and the necessity for binding the Dominions to the Mother Country, and all the rest of it, besides all we have heard is to be done by Preference and in various ways, it has never been suggested that it ought to be done in the reasonable way of encouraging people to come to this country by saying, "Well, you pay the absentee tax and come here, and we will make an abatement, and consider that in the tax imposed here." I suggest to the Chancellor of the Exchequer that, if he thinks what I am saying is not worth considering—and lots of people hold that view—then let him go to the Agents-General of any of our Dominions who are here and ask them if what I have said is not true, and they will say, "It is perfectly true, and what he states absolutely represents for the moment the view which is held in most of the Oversea Dominions on this matter."
§ Mr. LLOYD GEORGE
What they were concerned about was the Canadian or Australian who has come over here to spend a few years for the education of his children, or simply to visit this country, but who intended to return to the Colony, would be taxed not merely on the income received here—that they did not object to—but that they had been taxed upon the income which was left in Australia. I think the statement in the "Times" probably related to something which happened about a fortnight ago. The "Times," as a rule, is more up-to-date than that, but on this occasion they have got hold of something which happened a fortnight or three weeks ago, and which has been submitted to the Agents-General.
Mr. WILLIAM REDMOND
What the right hon. Gentleman says is perfectly true, but I think I am correct in saying that the 392 protest has reference to the new tax which is proposed by this Budget, and that is the taxing of money which is not earned in this country at all. I am sure the right hon. Gentleman would be the last to deny that protests have been made with regard to this new proposal. I am not pressing the point in any unfriendly spirit, but I know a strong opinion is held abroad on the matter. This year I happened to go through all those Dominions, and wherever I went I met a number of politicians, and one of the things they mentioned and of which they complained was this system. I hope the right hon. Gentleman will look into it, and if he will remedy it he will earn appreciation for himself in many distant parts of the world.
§ Sir P. MAGNUS
I am in general agreement with the remarks of the hon. Gentleman, but I desire to draw attention to the terms of the New Clause which I think the right hon. and learned Gentleman opposite treated with scant fairness, and on which he somewhat unwisely threw ridicule. The Clause has given rise to a very interesting Debate on a question which demands the careful consideration of the Government. The Chancellor of the Exchequer seemed to deal with the subject of the Clause only in the last few words of his speech, and the Debate generally has covered a much wider ground than was intended, it seems to me, to be covered by the Clause, which deals with a very small matter, and very much less than was supposed by the Chancellor, or by the hon. Gentleman who has just spoken. I do not think the Clause has anything to do with the objection to the payment of Income Tax in this country as well as in one of the Dominions. That is a much larger question which formed the subject of many of the speeches. The Clause merely asks that in assessing one's income in this country, which may be derived from dividends or income from Dominions or Colonies, one may, in filling in the form, deduct the amount of Income Tax charged in the Dominion or Colony. Surely that is a very reasonable proposition, and would make little difference to the revenue. Let us suppose the total income is £100, and that there is an Income Tax of 1s. in the £ in the country from which the money comes, the man receives £95 here, and surely he ought not to be required to pay 1s. 4d. in the £ on £100. That is the whole question, and I hope the Chancellor will accept the Amendment.
§ Mr. FELL
This is a matter which requires consideration by the Chancellor, because if he does not agree to this Clause he will be effecting a change in the law as it is at present. This Clause, as far as I can understand it, carries out exactly the present method of taxation on Colonial incomes received here. If a man receives a net amount of £95 from abroad, £5 being deducted, in London he would pay 1s. 3d. not on £100 but on the net sum of £95. It would be a most grievous thing if by any misunderstanding it should be thought that the taxation is not on the net income received in this country.
§ Mr. FELL
That is all this Clause asks and if there is any doubt thrown on it we must have the present law made clear. If it is accumulated abroad there is a special Clause, but this Clause only deals with charging the tax on the net sum, and has nothing to do with double duties or Colonial duties and English duties.
§ Mr. LLOYD GEORGE
There is absolutely no change in that respect. Clause 5 covers the possibility mentioned by the hon. Gentleman.
§ Mr. CHAMBERLAIN
Take the case put by my hon. Friend of an income of £100 received in a British Colony, and £5 is paid in taxes to that Colony and £95 remitted here. You have to pay Income Tax on £95. But if the money is accumulated in the country in which it is received, will not the taxpayer resident in this country have to pay British Income Tax on £100 under the new provision, instead of £95?
§ Mr. LLOYD GEORGE
No. If the right hon. Gentleman will look at Clause 5, we propose that the same deduction will be made in respect of income arising out there as is made now in respect of income remitted to this country. We do not propose any alteration in the present practice. The hon. Gentleman has rightly stated the practice and we extend that practice in the other cases.
§ Mr. BOOTH
There is one difficulty to my mind, and that is the definition of the term "Income Tax." I do not at all agree that this is such a very simple matter. We are face to face in this country with the proposal for a larger Income Tax in order to remit local taxation—that is to say, in order to relieve local rates. It is 394 quite possible that the Colonies may put on a large Income Tax in order to relieve their local rates. It does not at all follow that what is called Income Tax in the future will mean exactly what it has meant in the past. The Colonies might put on a tax of even 10s. in the £ in order to clear all their local rates. We do not know what they will do; they are not under our control. Hon. Members opposite have spoken of a 5 per cent. deduction. That argument has no weight with me, because they cannot guarantee anything of the kind. If we go into the Income Tax of the Colonies we shall get on foreign ground, and find ourselves in great difficulty. If we ignore their taxes, as we do at present, we know where we are, and we shall not become involved in inter-Colonial controversies. I object to the introduction of any such Clause as that now proposed. Our first duty is to the British Exchequer, and not to make arrangements which the Colonies may think more favourable to them. If the positions were reversed, we should not make the slightest impression upon any Colonial Legislature by putting forward such arguments as have been brought here to-night. Let us defend our own cash-box, and levy whatever Income Tax we feel we have a right to do in this country, and not go into the complicated questions of Income Tax in Australia and elsewhere.
§ Sir F. BANBURY
I think the hon. Gentleman opposite does not really understand the Amendment. It does not in the least matter what is the amount of Income Tax imposed by the Colony. All the Amendment says is that if an Income Tax is charged upon the revenue arising in a Colony, an additional Income Tax shall not be charged upon that sum in England. It does not matter whether it is 1s. or 10s.; the amount that has to be paid in the Colony is deducted before the sum is assessed here. The matter is absolutely simple, and I think that for once the hon. Member for Pontefract has made a mistake.
§ Sir A. MARKHAM
If the hon. Baronet who has just sat down had carefully read the Amendment, and had followed the speech in which the Amendment was carefully explained by the hon. Member for 395 London University, he would not have made the statement he has made. I want to ask the Attorney-General a question. If £100 is derived by a man living in Australia, there is an Income Tax of 1s. in the £, and the recipient receives an income of £95, but if that £95 is remitted here, what does that man pay in Income Tax? He is only charged on the £95. If that is so, what is the use of this Amendment, which I submit is out of order?
§ Mr. MACMASTER
The amount of income taxable in this country, less the Income Tax paid in the Dominion or in Colonies, is a comparatively small affair—
§ Sir A. MARKHAM
May I, Mr. Speaker, ask your ruling on a point of Order on the Amendment now before the House? The Amendment provides, "That income received in the United Kingdom from investments in British Possessions and Colonies shall be assessable to Income and Super-tax under this Act after the deduction of such income," and so on. Seeing that that is the existing law, how can this Amendment be in order?
§ Mr. MACMASTER
I am only endeavouring to point out what I understand to be the meaning of this Clause. I understand it to mean that there will be no Income Tax paid upon money which has paid any form of Income Tax in the Colonies. That is not the impression of people abroad in British Dominions. A small amount may be deducted under the provisions of this Clause, which is comparatively unimportant one way or another. That is not what affects me. But it is the fact that money sent here, and which may have accumulated becomes subject to tax again in this country. It ought to be perfectly possible for there to be some sort of reciprocal arrangement. In many of our Dominions there are reciprocal arrangements founded upon Statute by which in certain specified cases Income Tax paid in the Colonies is deducted from the amount of tax that is assessable in this country. That works very well; but that is a very different thing to what is proposed here. I am not 396 very much surprised, even if this Amendment is accepted, to find that there will be a very slight relief.
§ Mr. WORTHINGTON EVANS
I thought—and I will be very much obliged to the Chancellor if he will say what is the actual fact—that the Income Tax in future, owing to Clause 5, was to be payable on the gross and not on the net. This Amendment is designed to make English Income Tax payable on the net and not on the gross income. Under the law as it stands to-day, Income Tax is only payable on the net amount received from abroad—after Income Tax, and after deducting any amounts which are not remitted at home. Under Clause 5, he is no longer to be charged on the net amount remitted. He is to be charged, subject to something which is reserved in the Clause, on the amount of income earned whether remitted or not. There are some provisions in Clause 5, and it may be that concealed in these provisions is the difference between gross and net. I ask the Chancellor of the Exchequer this. Under the new Clause 5, the Income Tax is payable upon income whether remitted or not. Take the case of £100 of income in Australia. It is quite true that Australia takes away £5 for Income Tax, but if anyone is making his declaration for Income Tax here, he is bound to say that his income in Australia is £100, and not £95. What I ask the Chancellor of the Exchequer is, whether, under Clause 5, British Income Tax is payable upon £100 or upon £95? I cannot find any words that show it is payable upon £95, and if it is payable on £100, and not £95, then this Amendment is surely needed.
§ Mr. LLOYD GEORGE
If the hon. Gentleman will look at Clause 5 he will find that in the case of income not received in the United Kingdom the same deductions and allowances are allowed as if it had been so received. That means that if you pay upon £95 in the one case you pay upon £95 in the other.
§ Mr. WORTHINGTON EVANS
May I point out to the right hon. Gentleman that in the colony the Income Tax would be paid upon £100, and not upon £95. If it means you pay on the same amount in both places then in England you also pay on the £100.
§ Mr. HENRY TERRELL
A great deal of confusion is caused in not distinguishing between income received in this country from business carried on abroad 397 and income received by persons resident in this country in respect of securities, stocks, and shares abroad. In the first case, in respect of profits derived from business carried on abroad, the amount received in England is only taxed for Income Tax on so much of this profit as the man chooses to bring into the country. Neither under the present law, nor the law as amended by this Bill, will a man carrying on business abroad be taxed upon anything beyond so much of his income as he brings into this country. If a man having a business abroad chooses to turn that business into a limited liability company, if he no longer, in fact, carries on the business as a private business but as a company, and he receives an income arising from securities, stocks or shares in this company established abroad, then he is taxed, not only upon so much of that income as he chooses to bring into this country, but, under Section 5, upon the whole of the income which he derived from the whole of those securities, stocks, and shares. The income he receives from his shares in the company is the amount of dividend that is paid upon those shares. If the company pays a dividend of £100 upon a share, the income upon that share is £100, and he will be taxed upon that £100 in the country or the colony, and he will also be taxed here, not only upon the amount he brings in from the colony, but upon the whole £100, because the whole £100 is income arising from those stocks, shares, or securities. I suggest to the Attorney-General that the Chancellor of the Exchequer is quite mistaken in thinking that the case will in any way be covered by the words introduced in this connection. Income not received in the United Kingdom is to be subject to the same deductions and allowances as if it had been so received. In the United Kingdom there is no deduction allowed under the Act in respect of Income Tax paid in a foreign country, because the only amount received here is the amount after that deduction has been made. That refers to the deductions and allowances made under Schedule D of the Act of 1873 in respect of income paid in this country. When he receives income in this country he is not taxed on the whole amount, but he is allowed certain allowances and deductions under the existing law, and it is to those allowances and deductions that that Clause in this Section refers, and not to the Income Tax in a foreign country. The present Acts have nothing to do with that.
398 The net result is that in the case of stocks, shares, and securities a man receiving the dividends from shares which he holds in Australia will have to pay out of those dividends the Income Tax charged in Australia, and then he will have to pay Income Tax under this Clause in this country on the whole amount of the dividends, including that which has been deducted in Australia. I do not think the Attorney-General will deny that for a moment. Is it not manifestly clear on the construction of Section 5 that a man in that case having shares in a company in Australia so entitled to a dividend in Australia of £100 will pay tax in Australia and when he comes to England to make his declaration he will be taxed again in England upon the whole £100? I challenge the Attorney-General to say that this is not so under this Clause. The deductions to which the Chancellor of the Exchequer referred had nothing whatever to do with this case. Those deductions entitled a man receiving his income from abroad to certain deductions in respect of the money which he receives in this country, and they could not have anything to do with a deduction made in the Colonies in respect of the Income Tax he has paid there. I think the true construction of Section 5 ought to be made perfectly clear, and if it cannot be made clear, this Amendment should be introduced to make it perfectly clear. It is no use passing a Section of this kind until we know what is its real construction, and we should have it made clear that what is proposed will do what is intended.
§ Mr. PRETYMAN
Can the learned Attorney-General tell us what is meant by the same deductions and allowances?
§ Mr. BUTCHER
I think right hon. Gentlemen sitting on the Treasury Bench might, at least, arrange to say the same things on the same subject at different times. I have listened to all this Debate, and in the earlier stages of it the Attorney-General told us that a man would be called upon to pay Income Tax in this country on the gross amount which he gets from a Colony, and not the net amount; or, in other words, upon the amount, plus the tax, which he has paid in the Colony. I want to know whether it is a fact that the English Income Tax would be charged upon the gross amount received from the Colony? Am I wrong in that? I understand that I am right. The Debate has gone on for 399 over an hour upon that hypothesis, and the object of the Amendment is to say that which the Attorney-General says is the existing practice is wrong, and ought to be amended. The general subject we have been discussing is whether we ought to amend the existing law by making the Income Tax in England payable upon the net amount and not upon the gross. That has been resisted by the Treasury Bench, and only two minutes ago the Chancellor of the Exchequer told us, to the surprise of most of us, that we have been all wrong all this time, and that the true position is that at the present moment the English Income Tax is payable upon the net amount, and not upon the gross. If that is the real fact, what on earth have we been wasting over an hour's time for? That is exactly what my hon. Friend's Amendment tries to establish, that the Income Tax is payable upon the net amount. Before the Debate closes and we divide upon a subject, which the Chancellor of the Exchequer admits is of considerable importance, I really think that it would be only fair to the House that the Attorney-General should tell us whether he is right, or whether the Chancellor of the Exchequer is right, or whether they are are both wrong, and somebody else is right. It is quite clear we cannot intelligently vote upon this Amendment, which the Chancellor of the Exchequer says is entirely unnecessary, and which the Attorney-General says is not unnecessary but ought to be resisted without an answer, and I would ask the Attorney-General if he would kindly say whether I am right in the interpretation I have put upon it.
§ Mr. G. D. FABER
There seems to be a considerable difference of opinion, and perhaps I may be allowed to put the concrete case once again. There is £100 income received in Australia. A shilling Income Tax is paid upon it and £95 is remitted to this country. Is the Income Tax here of 1s. 3d. in the £ payable upon the £95 received here, or upon the £100 earned in Australia? I think one is entitled to in answer to that question. A good deal "will depend upon the answer. Will the Income Tax be chargeable upon the £100 or upon the £100 minus the £5? It is a very simple question, but there seems a great deal of difference as to the fact. I am sure the right hon. Gentleman, with his well-known courtesy, will give me an answer.
§ Sir J. SIMON
I have nothing at all to add to the explanation very fully given by my right hon. Friend the Chancellor of the Exchequer.
§ Mr. HOHLER
I should have thought the Attorney-General, in response to the appeal, would have told us what is the position. May I say what I understand is the position. At the present time it is the nett income that is received in this country that is liable to be taxed, and, of course, that income is entitled to the deduction. Under this Clause you are now taxing the whole of the income earned in the Colony wholly without regard to any Income Tax paid there. You will tax the whole £100 here because it is earned abroad. I can find nothing in this Section which provides for any allowance or reduction whatsoever, and the £100 which pays Income Tax in the Colony will also pay Income Tax here. I should be glad if the Attorney-General will say if the law is otherwise, because that is the whole point of the Debate.
§ Major ARCHER-SHEE
I understand the Chancellor of the Exchequer to say the sum on which Income Tax is payable is, according to Clause 5, the whole income received in the United Kingdom, subject
"to the same deductions and allowances as if it had been so received and to a deduction on account of any annual interest or any annuity or other annual payment payable out of the income to a person not resident in the United Kingdom."
Does the right hon. Gentleman mean to say Income Tax paid in Australia and charged by the Australian Government is an annual payment or is it a deduction in the form of annuity or annual interest? I fail to see that it comes under either head. It is an exceedingly important point and we ought to have a clear explanation before we divide.
§ Mr. PETO
In view of the words in the Clause itself—Income Tax in respect of income "arising"—I wish to point out that "arising" is a very complicated word and I do not think we should make business for lawyers in the future. We ought therefore now to get a clear definition from the Law Officers on this point.
§ Mr. HAYES FISHER
This is really important. It is the last opportunity we have for clearing up this matter. It is especially important to those who come over here in increasing numbers; they 401 have a right to know clearly the effect of this law which will so seriously affect their incomes. The Clause has been on the Paper many days. The right hon. Gentleman has had the great advantage of consulting experts under the Gallery: they can tell him whether or not this is the law, and there is no excuse for giving us entirely different opinions as to the effect of that. We have no reason on this side to complain of want of attention or courtesy, either on the part of the Chancellor of the Exchequer or of the Attorney-General all through this Debate, but to-night I think the House is not being treated with fairness and patience. One would have thought the Chancellor of the Exchequer and the Attorney-General could have agreed upon the interpretation they would put upon this Clause, and if either of them, either through modesty or by reason of the rules
§ of the House, is prevented addressing it for the second time, surely the Secretary to the Treasury has had ample opportunity to confer with the experts from the Treasury and Somerset House and could have learnt the law from them. I cannot help thinking that as the Front Bench is protected by the guillotine that is the reason why, now the Debate is becoming intricate and uncertain in its results, we cannot get a clear answer. Perhaps it is because at eleven o'clock we can raise our voices no more, can ask no further questions, and can obtain no further explanations, that they are deserting us to-night and are not giving us that information which on previous occasions they have accorded to us.
§ Question put, "That the Clause be read a second time."
§ The House divided: Ayes, 182; Noes, 262.405
|Division No. 194.]||AYES.||[10.45 p.m.|
|Agg-Gardner, James Tynte||Dickson, Rt. Hon. C. Scott||Keswick, Henry|
|Aitken, Sir William Max||Duke, Henry Edward||Kinloch-Cooke, Sir Clement|
|Archer-Shee, Major M.||Eyres-Monsell, Bolton M.||Lane-Fox, G. R.|
|Ashley, Wilfrid W.||Faber, George Denison (Clapham)||Law, Rt. Hon. A. Bonar (Bootle)|
|Astor, Waldorf||Faber, Capt. W. V. (Hants, W.)||Lloyd, George Butler (Shrewsbury)|
|Baird, J. L.||Fell, Arthur||Locker-Lampson, G. (Salisbury)|
|Baker, Sir R. L. (Dorset, N.)||Fisher, Rt. Hon. W. Hayes||Locker-Lampson, O. (Ramsey)|
|Baldwin, Stanley||Flannery, Sir J. Fortescue||Lockwood, Rt. Hon. Lieut.-Colonel A. R.|
|Banbury, Sir Frederick George||Fletcher, John Samuel||Lowe, Sir F. W. (Birm., Edgbaston)|
|Banner, Sir John S. Harmood-||Forster, Henry William||Lyttelton, Hon. J. C.|
|Baring, Maj. Hon. Guy V. (Winchester)||Garzoni, Francis John C.||Macmaster, Donald|
|Barlow, Montague (Salford, South)||Gardner, Ernest||Malcolm, Ian|
|Barnston, H.||Gastrell, Major W. Houghton||Mason, James F. (Windsor)|
|Bathurst, C. (Wilts, Wilton)||Gibbs, G. A.||Mildmay, Francis Bingham|
|Beach, Hon. Michael Hugh Hicks||Gilmour, Captain John||Mills, Hon. Charles Thomas|
|Beckett, Hon. Gervase||Glazebreek, Captain Philip K.||Morrison-Bell, Capt. E. F. (Ashburton)|
|Benn, Arthur Shirley (Plymouth)||Goldman, C. S.||Morrison-Bell, Major A. C. (Honiton)|
|Benn, Ion Hamilton (Greenwich)||Goldsmith, Frank||Mount, William Arthur|
|Bennett-Goldney, Francis||Grant, J. A.||Newdegate, F. A.|
|Bentinck, Lord H. Cavendish-||Gretton, John||Newton, Harry Kottingham|
|Bigland, Alfred||Guinness, Hon. Rupert (Essex, S. E.)||Nicholson, William G. (Petersfield)|
|Bird, A.||Guinness, Hon. W. E. (Bury S. Edmunds)||Nield, Herbert|
|Blair, Reginald||Gwynne, R. S. (Sussex, Eastbourne)||O'Neill, Hon. A. E. B. (Antrim, Mid)|
|Boscawen, Sir Arthur S. T. Griffith-||Haddock, George Bahr||Orde-Powlett, Hon. W. G. A.|
|Bowden, G. R. Harland||Hall, D. B. (Isle of Wight)||Ormsby-Gore, Hon. William|
|Boyton, James||Hall, Frederick (Dulwich)||Parker, Sir Gilbert (Gravesend)|
|Brassey, H. Leonard Campbell||Hamilton, C. G. C. (Ches., Altrincham)||Pease, Herbert Pike (Darlington)|
|Bridgeman, W. Clive||Hamilton, Lord C. J. (Kensington, S.)||Peel, Lieut-Colonel R. F.|
|Burn, Colonel C. R.||Hardy, Rt. Hon. Laurence||Perkins, Walter Frank|
|Butcher, John George||Harrison-Broadley, H. B.||Peto, Basil Edward|
|Campbell, Captain Duncan F. (Ayr, N.)||Harris, Leverton (Worcester, East)||Pollock, Ernest Murray|
|Campion, W. R.||Helmsley, Viscount||Pretyman, Ernest George|
|Carlile, Sir Edward Hildred||Henderson, Major H. (Berks, Abingdon)||Pryce-Jones, Col. E. (M'tgom'y B'ghs)|
|Cassel, Felix||Henderson, Sir A. (St. Geo., Han. Sq.)||Quilter, Sir William Eley C.|
|Castlereagh, Viscount||Herbert, Hon. A. (Somerset, S.)||Randles, Sir John S.|
|Cave, George||Hewins, William Albert Samuel||Rawlinson, John Frederick Peel|
|Cecil, Evelyn (Aston Manor)||Hibbert, Sir Henry F.||Ronaldshay, Earl of|
|Cecil, Lord Hugh (Oxford University)||Hills, John Waller||Rothschild, Lionel de|
|Cecil, Lord R. (Herts, Hitchin)||Hill-Wood, Samuel||Royds, Edmund|
|Chamberlain, Rt. Hon. J. A.||Hoare, S. J. G.||Salter, Arthur Clavell|
|Clay, Captain H. H. Spender||Hohler, G. F.||Samuel, Sir Harry (Norwood)|
|Clive, Captain Percy Archer||Hope, Harry (Bute)||Samuel, Samuel (Wandsworth)|
|Clyde, J. Avon||Hope, James Fitzalan (Sheffield)||Sanders, Robert A.|
|Craig, Captain James (Down, E.)||Hope, Major J. A.||Sanderson, Lancelot|
|Craig, Norman (Kent, Thanet)||Horne, E.||Sassoon, Sir Philip|
|Craik, Sir Henry||Horner, Andrew Long||Scott, Sir S. (Marylebone, W.)|
|Crichton-Stuart, Lord Ninian||Hunt, Rowland||Smith, Harold (Warrington)|
|Currie, George W.||Hunter, Sir C. R.||Spear, Sir John Ward|
|Dalrymple, Viscount||Jardine, Ernest (Somerset, E.)||Stanier, Beville|
|Denison-Pender, J. C.||Joynson-Hicks, William||Stanley, Hon. G. F. (Preston)|
|Denniss, E. R. B.||Kerry, Earl of||Starkey, John R.|
|Staveley-Hill, Henry (Staffordshire)||Touche, George Alexander||Willoughby, Major Hon. Claud|
|Steel-Maitland, A. D.||Tryon, Captain George Clement||Wills, Sir Gilbert|
|Stewart, Gershom||Tullibardine, Marquess of||Wilson, A. Stanley (York, E. R.)|
|Strauss, Arthur (Paddington, North)||Walrond, Hon. Lionel||Wood, Hon. E. F. L. (Ripon)|
|Swift, Rigby||Warde, Colonel C. E. (Kent, Mid)||Wood, John (Stalybridge)|
|Sykes, Sir Mark (Hull, Central)||Watson, Hon. W.||Worthington Evans, L.|
|Talbot, Lord E.||Weigall, Captain A. G.||Younger, Sir George|
|Terrell, Henry (Gloucester)||Weston, Colonel J. W.|
|Thomas-Stanford, Charles||Wheler, Granville C. H.||TELLERS FOR THE AYES.—Sir|
|Thomson, W. Mitchell (Down, N.)||White, Major G. D. (Lancs., Southport)||J. D. Rees and Sir Philip|
|Thynne, Lord Alexander||Williams, Colonel R. (Dorset, W.)|
|Abraham, William (Dublin, Harbour)||Ftrench, Peter||Macdonald, J. M. (Falkirk Burghs)|
|Acland, Francis Dyke||Field, William||McGhee, Richard|
|Addison, Dr. Christopher||Fiennes, Hon. Eustace Edward||Maclean, Doneld|
|Adkins, Sir W. Ryland D.||Fitzgibbon, John||MacVeagh, Jeremiah|
|Agnew, Sir George William||Flavin, Michael Joseph||M'Callum, Sir John M.|
|Allen, Arthur A. (Dumbartonshire)||Furness, Sir Stephen Wilson||M'Curdy, C. A.|
|Allen, Rt. Hon. Charles P. (Stroud)||Gelder, Sir William Alfred||McKenna, Rt. Hon. Reginald|
|Armitage, R.||George, Rt. Hon. D. Lloyd||M'Laren, Hon. H. D. (Leics.)|
|Arnold, Sydney||Gladstone, W. G. C.||M'Laren, Hon. F. W. S. (Lincs., Spalding|
|Baker, Harold T. (Accrington)||Glanville, H. J.||Manfield, Harry|
|Baker, Joseph Allen (Finsbury, E.)||Goddard, Sir Daniel Ford||Markham, Sir Arthur Basil|
|Balfour, Sir Robert (Lanark)||Goldstone, Frank||Marshall, Arthur Harold|
|Baring, Sir Godfrey (Barnstaple)||Greig, Colonel J. W.||Meagher, Michael|
|Barlow, Sir John Emmott (Somerset)||Grey, Rt. Hon. Sir Edward||Meehan, Francis E. (Leitrim, N.)|
|Barnes, George N.||Griffith, Rt. Hon. Ellis Jones||Meehan, Patrick J. (Queen's Co., Leix.)|
|Beale, Sir William Phipson||Guest, Hon. Frederick (Dorset, E.)||Millar, James Duncan|
|Beck, Arthur Cecil||Gulland, John William||Molloy, Michael|
|Benn, W. W. (T. Hamlets, St. George)||Gwynn, Stephen Lucius (Galway)||Molteno, Percy Alport|
|Bentham, George Jackson||Hackett, J.||Mond, Rt. Hon. Sir Alfred|
|Bethell, Sir John Henry||Hancock, John George||Montagu, Hon. E. S.|
|Black, Arthur W.||Harcourt, Rt. Hon. Lewis (Rossendale)||Mooney, John J.|
|Boland, John Plus||Harcourt, Robert V. (Montrose)||Morgan, George Hay|
|Booth, Frederick Handel||Hardie, J. Keir||Morison, Hector|
|Bowerman, C. W.||Harmsworth, Cecil (Luton, Beds.)||Munro, Rt. Hon. Robert|
|Brady, P. J.||Harvey, A. G. C. (Rochdale)||Murphy, Martin J.|
|Brockiehurst, William B.||Harvey, T. E. (Leeds, W.)||Needham, Christopher Thomas|
|Brunner, J. F. L.||Haslam, Lewis (Monmouth)||Neilson, Francis|
|Bryce, J. Annan||Havelock-Allan, Sir Henry||Nicholson, Sir Charles N. (Doncaster)|
|Buckmaster, Sir Stanley O.||Hayden, John Patrick||Nolan, Joseph|
|Burns, Rt. Hon. John||Hayward, Evan||Norton, Captain Cecil W.|
|Burt, Rt. Hon. Thomas||Helme, Sir Norval Watson||Nugent, Sir Walter Richard|
|Byles, Sir William Pollard||Hemmerde, Edward George||Nuttall, Harry|
|Carr-Gomm, H. W.||Henderson, Arthur (Durham)||O'Brien, Patrick (Kilkenny)|
|Cawley, H. T. (Heywood)||Henry, Sir Charles||O'Connor, T. P. (Liverpool)|
|Chancellor, Henry George||Hewart, Gordon||O'Doherty, Philip|
|Churchill, Rt. Hon. Winston S.||Higham, John Sharp||O'Donnell, Thomas|
|Clancy, John Joseph||Hinds, John||O'Dowd, John|
|Clough, William||Hodge, John||O'Malley, William|
|Clynes, John R.||Hogge, James Myles||O'Neill, Dr. Charles (Armagh, S.)|
|Collins, Godfrey P. (Greenock)||Holt, Richard Durning||O'Shaughnessy, P. J.|
|Collins, Sir Stephen (Lambeth)||Hope, John Deans (Haddington)||O'Sullivan, Timothy|
|Compton-Rickett, Rt. Hon. Sir J.||Howard, Hon. Geoffrey||Palmer, Godfrey Mark|
|Cornwall, Sir Edwin A.||Hudson, Walter||Parker, James (Halifax)|
|Craig, Herbert J. (Tynemouth)||Hughes, Spencer Leigh||Parry, Thomas H.|
|Crooks, William||Illingworth, Percy H.||Pearce, William (Limehouse)|
|Crumley, Patrick||John, Edward Thomas||Pease, Rt. Hon. Joseph A. (Rotherham)|
|Cullinan, John||Jones, Edgar (Merthyr Tydvil)||Phillips, John (Longford, S.)|
|Dalziel, Rt. Hon. Sir J. H. (Kirkcaldy)||Jones, H. Haydn (Merioneth)||Pratt, J. W.|
|Davies, David (Montgomery Co.)||Jones, J. Towyn (Carmarthen. East)||Price, C. E. (Edinburgh, Central)|
|Davies, Ellis William (Eifion)||Jones, Leif (Notts. Rushcliffe)||Priestley, Sir Arthur (Grantham)|
|Davies, Timothy (Lincs., Louth)||Jones, W. S. Glyn- (T. H'mts, Stepney)||Priestley, Sir W. E. B. (Bradford, E.)|
|Davies, Sir W. Howell (Bristol, S.)||Jowett, Frederick William||Pringle, William M. R.|
|Dawes, J. A.||Joyce, Michael||Radford, G. H.|
|De Forest, Baron||Kellaway, Frederick George||Raffan, Peter Wilson|
|Delany, William||Kelly, Edward||Rea, Rt. Hon. Russell (South Shields)|
|Denman, Hon. R. D.||Kennedy, Vincent Paul||Rea, Walter Russell (Scarborough)|
|Devlin, Joseph||Kenyon, Barnet||Reddy, M.|
|Dickinson, Rt. Hon. Willoughby H.||Kilbride, Denis||Redmond, John E. (Waterford)|
|Dillon, John||King, J.||Redmond, William (Clare, E.)|
|Donelan, Captain A.||Lambert, Rt. Hon. G. (Devon, Molton)||Redmond, William Archer (Tyrone, E.)|
|Doris, William||Lambert, Richard (Wilts, Cricklade)||Rendall, Athelstan|
|Duffy, William J.||Lardner, James C. R.||Richardson, Albion (Peckham)|
|Duncan, C. (Barrow-in-Furness)||Law, Hugh A. (Donegal, West)||Richardson, Thomas (Whitehaven)|
|Duncan, Sir J. Hastings (Yorks, Otley)||Lawson, Sir W. (Cumb'rld, Cockerm'th)||Roberts, Charles H. (Lincoln)|
|Edwards, John Hugh (Glamorgan, Mid)||Levy, Sir Maurice||Roberts, G. H. (Norwich)|
|Elverston, Sir Harold||Lewis, Rt. Hon. John Herbert||Roberts, Sir J. H. (Denbighs)|
|Esmonde, Dr. John (Tipperary, N.)||Lundon, T.||Robertson, John M. (Tyneside)|
|Esmonde, Sir Thomas (Wexford, N.)||Lyell, Charles Henry||Robinson, Sidney|
|Falconer, James||Lynch, A. A.||Roch, Walter F. (Pembroke)|
|Fenwick, Rt. Hon. Charles||Macdonald, J. Ramsay (Leicester)||Roche, Augustine (Louth)|
|Roe, Sir Thomas||Taylor, John W. (Durham)||Whittaker, Rt. Hon Sir Thomas P.|
|Rowlands, James||Taylor, Theodore C. (Radcliffe)||Whyte, A. F. (Perth)|
|Rowntree, Arnold||Taylor, Thomas (Bolton)||Wiles, Thomas|
|Runciman, Rt. Hon. Walter||Tennant, Rt. Hon. Harold John||Wilkie, Alexander|
|Russell, Rt. Hon. Thomas W.||Thorne, G. R. (Wolverhampton)||Williams, Aneurin (Durham, N. W.)|
|Samuel, J. (Stockton-on-Tees)||Thorne, William (West Ham)||Williams, Penry (Middlesbrough)|
|Scanlan, Thomas||Toulmin, Sir George||Williamson, Sir Archibald|
|Scott, A. MacCallum (Glas., Bridgeton)||Verney, Sir Harry||Wilson, Rt. Hon. J. W. (Worcs., N.)|
|Seely, Colonel Rt. Hon. J. E. B.||Walsh, Stephen (Lancs., Ince)||Wilson, W. T. (Westhoughton)|
|Sheehy, David||Walters, Sir John Tudor||Winfrey, Sir Richard|
|Sherwell, Arthur James||Wardle, George J.||Wing, Thomas Edward|
|Shortt, Edward||Waring, Walter||Yeo, Alfred William|
|Simon, Rt. Hon. Sir John Allsebrook||Warner, Sir Thomas Courtenay T.||Young, William (Perth, East)|
|Smith, Albert (Lancs., Clitheroe)||Watt, Henry A.||Yoxall, Sir James Henry|
|Smith, H. B. L. (Northampton)||Wedgwood, Josiah C.|
|Smyth, Thomas F. (Leitrim, S.)||White, J. Dundas (Glasgow, Tradeston)|
|Spicer, Rt. Hon. Sir Albert||White, Sir Luke (Yorks, E. R.)||TELLERS FOR THE NOES.—Mr.|
|Sutherland, J. E.||White, Patrick (Meath, North)||William Jones and Mr. Webb.|
|Sutton, John E.||Whitehouse, John Howard|