§ (1) Where sales or transactions are carried out on behalf of a non-resident person through a broker in the ordinary course of his business as such, and the broker satisfies the conditions required to be satisfied for the purposes of this Section, then, notwithstanding that the broker is a person who acts regularly for the non-resident person as such broker the non-resident person shall not be chargeable to Income Tax in the name of that broker in respect of profits or gains arising from those sales or transactions.
§ (2) The conditions required to be satisfied for the purposes of this Section are that the broker must be a person carrying on bonâ fide the business of a broker in Great Britain or Northern Ireland, and that he must receive in respect of the business of the nonresident person which is transacted through him remuneration at a rate not less than that customary in the class of business in question.
§ (3) In this Section the expression "broker" includes a general commission agent.
§ (4) Rule 10 of the General Rules shall have effect subject to the provisions of this Section.—[Mr. Guinness.]
§ Brought up, and read the First time.
The FINANCIAL SECRETARY to the TREASURY (Mr. Guinness)I beg to move, "That the Clause be read a Second time."
This Clause is designed to deal with a great difficulty which has arisen owing to brokers and general commission agents having been held liable under recent legal decisions to pay Income Tax on the profits arising to non-residents on sales carried out in this country. The trouble 1123 has arisen especially in the case of those commission agents who deal with produce and raw material when, though the transactions are carried out by men classed as commission agents or brokers, their relation with the non-resident principals is such as to make them, under the existing law, liable to Income Tax on the sales profit in this country accruing to their principals.
We propose to deal with this situation by excluding cases where the transaction is carried out on behalf of a nonresident person through a broker in the ordinary course of his business as such, provided that the broker receives in respect of the business remuneration at a rate not less than that customary in the class of business in question, and notwithstanding the fact that the broker may be acting regularly for the non-resident person as such. Where the agent acts exclusively for the particular non-resident principal he will, of course, remain liable for the Income Tax of that principal, and I believe that the law, as we propose to make it, will be in accordance with the intention expressed by Parliament when on the recommendation of Mr. McKenna they last dealt with this subject. Mr. McKenna took steps to exempt the entrepôt and international trade from any liability to British Income Tax on account of the profits of the foreign principal, but, in practice, since certain decisions have been given in the Courts, this class of entrepôt trade has been brought into the net, because this is a type of business in which the commission agent really does not know the ultimate destination of the goods. He only knows to whom he sells the goods, but he has not any evidence as to whether the broker to whom he sells is acting for a foreign principal or for someone in this country.
Naturally in the ordinary course of trade this information is very jealously guarded. The position has now arisen that a large number of these brokers and general commission agents live in fear of being charged on such of the profits of the foreign produce merchants as are notionally attributable to this market, although it is quite beyond their power to get their foreign principals to make any contribution to the tax for which the broker is now held liable. This tax at 1124 the present time is in fact not generally collected but unless the law can be amended to deal with this difficulty, it will be the duty of the Inland Revenue to raise many assessments. If that course becomes necessary there is the danger of disastrous results to our vast international and entrepôt trade. Much of the business which is carried on in this country is concerned with goods which never reach these shores at all. Java sugar is sold through the London market to Indian merchants, and Scandinavian timber is sold through the London timber brokers to merchants in Holland and Belgium. Not even the world-wide reputation which the London broker has built up will enable him to keep this trade if the foreign seller discovers that by using the London broker he lays himself open to a charge for Income Tax which he can escape by dealing directly with the ultimate consumer.
If we make this amendment of the law I believe it will result eventually in a considerable profit to the revenue. At the present time the general commission agent is not generally brought into charge, and therefore we shall be losing nothing which is at present collected. Attempts to deal with this matter have revealed such difficulties that the Inland Revenue have found it impossible, short of causing a cataclysmic disturbance, in our existing trade methods, to raise assessments on this particular class of business. But if Parliament does not put the matter right the Inland Revenue will inevitably try to get this money and in doing that we shall drive a vast amount of this business, which is now going through London, into foreign channels, and we shall lose the taxes which we now collect on the profits made by the broker. The amount of income which would escape under the proposed Amendment is not very serious because Parliament in legislation in 1918 provided that it should only be that amount of the foreigner's profit which was notionally attributable to his selling profit in this market which should be charged, and that he should not be liable for the manufacturing or producing profit which arose in his own country.
Therefore the amount which might conceivably escape is only the difference between the c.i.f. price, approximately speaking, and the f.o.b. price when the charges for shipping, insurance and so 1125 forth have been deducted. It is therefore only a small amount of the foreigners' profit which is really at issue, and on the other hand we have this vast income earned by the brokers and the general commission agents which we might easily lose if the Inland Revenue began to assess them on this business which has so far been held to be exempt. The position is now that the present system, exempting international and entrepôt trade, has in practice proved unworkable, and I hope that the House will settle the difficulty by accepting this New Clause and avoiding the necessity of raising a tax on all this new field of taxation with the result of driving away the great business which is now done in the London market in agency, brokerage, finance and shipping.
§ 4.0 P.M.
§ Mr. WILLIAM GRAHAMThe Financial Secretary to the Treasury this afternoon has given a brief explanation of an important and complicated matter which was discussed at some length last year during the time we were in office, and at a time when very strong representations were made to us that there was a substantial hardship behind the effort to get some revenue from two classes of agents, who, theoretically at least, were outside the scope of British Income Tax. The difficulty of arguing a matter of this kind, first of all, is that it is very complex in character, and, secondly, the proposal of the Government appears on the surface of it to be fair and reasonable. But when we get down to the details of the case, I think I shall be able to show the House, briefly and as clearly as possible, that there is another side, and, as I regard it, a very dangerous side to this Clause. This goes back, of course, a long way in our Income Tax history, probably at least to 1842, but I do not propose to review anything like that period this afternoon. The short and simple position, as we found it prior to 1915, was that the man who was a special agent in this country—that is in a definite sense a. resident agent—was undoubtedly taxed, and the two classes who were outside the scope of any tax at all in respect of the foreign principal were the commission agent, whom I will call the man with the roving commission, and the broker. That was the position in 1915, so we can distinguish to-day three classes of agency: one which was undoubtedly liable to Income Tax on the profits which were made on behalf of 1126 the foreign principal and the other two who were not liable at all.
In 1915, Mr. McKenna introduced a Clause in this House mainly, I think, for two reasons. The first reason was that there had undoubtedly grown up some kind of collusive arrangement, under which these two classes of people were really acting as special agents and conducting what amounted in practice to a branch of the business in this country. In order to try and get at this form of collusion, Mr. McKenna introduced some proposals in 1915 which undeniably are the ground of our difficulty this afternoon. The other reason which, I think, actuated Mr. McKenna at the time was this. It appeared to be perfectly clear that there was being conducted under the two heads of agency which I have just described, and which so far were excluded from the tax, a class of business within this country which was in competition with taxed trades conducted here. You therefore had an unfair position as regards two classes of commerce, in that one was liable to the tax and the other trade in competition with it was not subject to the tax at all. That state of affairs was clearly indefensible, and, accordingly, mainly for the reason of collusion, this proposal was introduced in 1915.
I understand that the contention of the supporters of the present Clause is that that Clause of 1915 has been extended to cover classes of agency which were not intended by Mr. McKenna to be covered at all. I think it is very doubtful indeed whether that proposition could be supported. In any event, the next stage of this very important controversy—because I call anything important which covers millions of pounds worth of trade and may mean a great deal of revenue to Great Britain—was the consideration of this very problem by the Royal Commission on Income Tax in 1919. Far be it from me to suggest that everything published in that Report in 1920 is necessarily sacred and not to be departed from in any way, but I would remind the Chancellor of the Exchequer, because I think certain interests have got the upper hand of him in this matter, that on this point the Royal Commission was perfectly unanimous. First of all, they made it clear that they did not want to do anything at all to injure our entrepot trade—I do not admit that this does 1127 injure that class of trade at all—but they also went on to show that there were great advantages in what was virtually a resident agency in this country, and they also clearly showed that it was unfair that any trade carried on by people within this country should be at a disadvantage compared with trade conducted on behalf of foreign principals which was nevertheless within these shores. Accordingly they unanimously made the recommendation that the existing law should be extended to cover the broker who was acting for all practical purposes as resident agent.
The Chancellor of the Exchequer now proposes the very opposite of that definite and unanimous recommendation, because, in effect, what he says is this: I propose to make certain of the exemption of the broker and the general commission agent, and I do not propose to try to levy this tax at all. That is the extraordinary position at which we have arrived following the unanimous recommendation of the Royal Commission. He maintains the taxation on the special agent—I ought to have made that clear—but he now departs from everything that has been attempted as regards the broker and the general agent contrary to the unanimous recommendation of the Royal Commission on Income Tax in 1920. I regard that as a very serious departure. I am the last to suggest any taxation which is going to injure our international trade, especially at a time when we have widespread unemployment and when undoubtedly it is our duty to foster trade as much as we possibly can: but the important point here is one of taxation and whether we are going to allow outside of tax trade which is competing with British trade. The Royal Commission in 1919 made that unanimous recommendation, and a year ago, during one of our all-night sittings on the Finance Bill of that Say, we discussed this matter at some length on the floor of this House. It can hardly be denied that this is trade in competition with taxed trade within this country.
I want to remind the House also that all the legal decisions within recent times have been on the side of the Inland Revenue in this matter. I challenge the Chancellor of the Exchequer, in the course of his reply this afternoon, to name one legal decision which supports the course 1128 which he is now proposing to the House. The legal decisions support the Inland Revenue authorities, and, accordingly, the Government cannot come forward and say that they are in any difficulty at all as regards the legal aspects of their case. What is the practical point in this connection? It is this. If we give up the agent, who is in my judgment in many cases really carrying on a branch of some foreign principal in this country, under it may be a general agency or broker's business, because it is very difficult to say where the one ends and the other begins, we have no recourse at all against the foreign principal. We have no jurisdiction over him. Accordingly, from the point of view of revenue, it is perfectly fair to try to keep a reasonable hold—I do not put it higher than that—over the agent in this country. That hold the Chancellor of the Exchequer entirely gives up by this proposal, and I venture to suggest that, while on the surface there is something to be said for what is an apparent unfairness, he is really embarking on a very dangerous step in Income Tax practice, because he is going to put certain classes of British trade conducted within these shores at a manifest disadvantage compared with this trade still coming within these shores but, under the new principles being laid down by the right hon. Gentleman, not open to taxation.
There is only one other point I would put in opposing this new Clause. It has been argued by some critics that this is really a problem of double taxation. A year ago, when this matter was under consideration by the House, I took the view that there was not a very large element of the difficulty of double taxation in it, but it may be that a solution could be found along that line. Within recent times we have taken definite steps in the matter of double taxation, particularly within our Empire in a case like shipping, and, if I remember rightly, in certain other directions. If you can get some kind of reciprocal arrangement, there might be a case and there might be a way out of this difficulty. But there is certainly no real merit, in taxation, in the proposal which the Chancellor of the Exchequer now makes. I understand that the difficulty is that in practice this revenue is very difficult to collect The Financial Secretary indeed made that plain this afternoon. But that never was an argument for giving up what is quite 1129 clearly taxable material. When did the House of Commons ever agree to a proposition that you were to give up what could be legitimately taxed merely because there were difficulties, technical and other, in the collection? If the Chancellor of the Exchequer once makes a concession of that kind, a very large part of his revenue flies away. On all these grounds, I think that this is a bad proposal; I think the Government ought to have resisted it, as we resisted it in this House a year ago; and, accordingly, so far as we are concerned, we shall certainly divide against it this afternoon.
§ Mr. DENNIS HERBERTI must pay the right hon. Member for Central Edinburgh (Mr. W. Graham) a compliment on his ingenuity in finding his way to oppose this particular Clause. After all, he has a great and intense interest in the entrepôt trade of this country, and it seems to me that he is attempting here, by means of the Income Tax, to levy a protective tax, instead of doing it by means of a tariff. He wants to tax profits which are made on work done abroad in order to protect those who do similar work in this country. If he wants to do that, his proper course is to come out with a definite proposal for a tariff against these foreign manufactured goods. I would like to thank the Financial Secretary to the Treasury, the Chancellor of the Exchequer, and the Government for the way in which they have met those who have been associated with me and who were associated with me last year when we thought that we had the sympathy of the right hon. Gentleman who has just spoken. Even if there were anything in the argument put forward by the right hon. Gentleman, I venture to suggest—and I think the Chancellor of the Exchequer will agree with me—that the amount of business which would be driven away through the fear of this particular taxation would lose this country far more revenue than would be gained by an attempt to follow the counsels of the right hon. Gentleman.
The right hon. Gentleman the Financial Secretary to the Treasury, in the course of his speech, said that we should lose, or run the danger of losing, the Income Tax on the brokers' profits which are made in this country in connection with the business, but that is a very small part 1130 indeed of the revenue we are going to lose if that business is driven away from this country. Then, we not only lose the tax on the profits of that business, but the City of London loses that immensely larger business connected with freights, insurance, and the financial business of various kinds which this brokerage business brings in its train. It is not too much to say that, to use the right hon. Gentleman's own word, the result would be cataclysmic. Therefore, the House must discount, even if there were any thing very much in it otherwise, any fear that possibly some profits might escape taxation which would otherwise have been taxed under the law as it now stands.
There are two points to which I should like to draw the attention of the Chancellor of the Exchequer and the Financial Secretary. To one the Financial Secretary himself referred when he stated that, in fact, this tax, in so far as it is objectionable, has not been collected by the Inland Revenue. Of course, that has not always been the case, but when the right hon. Gentleman sitting opposite was in office last year, there were cases in which the Inland Revenue, under his régime, did refrain from putting the law as it then stood into force quite so hardly as they might have done, and we recognise with gratitude that the Inland Revenue have adopted that course, and adopted it in the interests of the revenue of this country. I venture to express the hope that, if this Clause goes through, as I hope it will, the Government will see that no attempt is made by the Inland Revenue to put in force, in regard to the past, the letter of the law as it stood in the past.
The other point is this: The Clause is, I believe, perfectly satisfactory to something like 90 per cent., if not more, of those whom the Government have been trying to meet, and I only venture to express the hope that, if there be 1, 5, or even 10 per cent. who might possibly not be protected by this Clause, although it is the intention of the Government to protect them, the Inland Revenue, in the spirit in which this Clause is being brought forward, will interpret it as far as possible in the way in which it is meant to be interpreted, and that, should there be a case of hardship, they will endeavour so far as they can to act up to the spirit of the Clause rather than, possibly, to any 1131 narrowness that there may be in the letter of it.
I would urge, in conclusion, that the really serious state of the law as it has stood in the past has been shown in practice during the last two years, as the Inland Revenue no doubt know, by the fact that a large amount of business has already been driven away from this country, and although it may be said that the tax which would be chargeable under the law as it now stands against some of these foreigners would be very small, that does not affect the threatened flight of business from this country, because if the foreigner sees that, with very little additional inconvenience, he can do his business elsewhere just as well, and profitably, and easily as he can in London, the smallest tax frightens him, because he thinks that if he is liable to tax at all, he cannot tell how much it will be in the future, and, therefore, he will go elsewhere with his business. We are very grateful to the Government for meeting us in this way, and we trust that they will stick to this Clause, and that the common sense of the House, in the interests of the taxation of this country, will support the Government.
Captain BENNMany of us listened with delight to the hon. Member for Watford (Mr. Herbert), to hear that so much consideration is being shown to this foreign trade. This is a new red light, but it is not quite as bright as it appears when one examines it, because the hon. Member objects to taxing the profits of a merchant, but we object to laying on a tax which will be passed on to the consumer. The hon. Member is prepared to support a tariff which the merchant will pass on to the consumer, but he is not prepared to support a tax which the merchant will pay himself.
§ Mr. HERBERTWill the hon. and gallant Member say why he cannot pass on the Income Tax if he can pass on a tariff?
Captain BENNThat, I think, would lead us rather further than the narrow limits of this Clause would allow, but it is very interesting to note, and I take leave to draw attention to, the distinction which the hon. Gentleman makes in opposing a tax imposed on a merchant 1132 and in supporting a tax passed on to the consumer. That comment was aroused by the interest excited by the hon. Member's able but somewhat surprising speech. I wish to ask a question which has been put to me by people interested in this Clause. I wish to ask how the Commissioners propose to find out when remuneration is "at a rate not less than that customary" in this class of business. I ask that, because some people fear that the application of this Clause will lead to methods, on the part of the Inland Revenue authorities, of an inquisitorial character, and if the right hon. Gentleman will tell us how, in his plans, he is proposing to deal with the determination of the question of what is the remuneration, I think it might set at rest doubts that are felt by many interested in the Clause.
Mr. GUINNESSThe exemption applies to agents who are paid commission agents, and not salaried agents.
Captain BENNThat is not quite the point. Are they to return their total receipts from their firms, and their total business done, or how will you ascertain that they are not paid more than the customary rate, even assuming that you know what the customary rate is?
§ Sir WILLIAM LANE-MITCHELLThe customary brokerage rate is well known, but if a large shipper here engaged a broker or commission agent to do his business for ⅛ per cent., when the regular commission was ½ per cent., it would be perfectly easy for the Income Tax authorities to check whether the full commission was being charged or not. I am glad the Government have brought in this Clause, as I happen to be a broker, and it is very interesting to me to know that, when you are accepting business from abroad, at least you cannot cut the commission. You must charge the full commission, or the Inland Revenue authorities will come down on you. If you were a produce agent dealing with goods all over the world, you would know how much waste of time there is in trying to get clear from the Income Tax liability in respect of the profits of your shipper abroad on these transactions. The hon. and gallant Member for Leith (Captain Benn) suggested that the Government were protect- 1133 ing the merchant. They are not protecting the merchant, but the produce broker and the commission agent on this side, who are now liable to Income Tax, and have no means of recovering it from the shippers abroad, on the profits they may make on these goods. This affects goods from every part of the world. I am offered every morning goods from China to go to any port in Europe, and you do not know where they are going. The Inland Revenue authorities say the agent is responsible because he handles the goods, but he does not know whether
§ they are going to Hamburg or Marseilles or anywhere else. It is a responsibility we ought not to have to bear, and the agents and brokers in the City of London are grateful to the Government for making this concession, which relieves us of these liabilities, which we ought not to be asked to bear.
§ Question put, "That the Clause be read a Second time."
§ The House divided: Ayes, 262; Noes, 68.
1135| Division No. 192.] | AYES. | [4.25 p.m. |
| Acland-Troyte, Lieut.-Colonel | Collins, Sir Godfrey (Greenock) | Hennessy, Major J. R. G. |
| Agg-Gardner, Rt. Hon. Sir James T. | Cooper, A. Duff | Henniker-Hughan, Vice-Adm. Sir A. |
| Albery, Irving James | Cope, Major William | Herbert, Dennis (Hertford, Watford) |
| Amery, Rt. Hon. Leopold C. M. S. | Couper, J. B. | Herbert, S. (York, N. R., Scar. & Wh'by) |
| Applin, Colonel R. V. K. | Courtauld, Major J. S. | Hoare, Lt.-Col. Rt. Hon. Sir S. J. G. |
| Ashley, Lt.-Col. Rt. Hon. Wilfrid W. | Craik, Rt. Hon. Sir Henry | Hogg, Rt. Hon. Sir D. (St. Marylebone) |
| Astor, Viscountess | Crawfurd, H. E. | Holbrook, Sir Arthur Richard |
| Atholl, Duchess of | Croft, Brigadier-General Sir H. | Homan, C. W. J. |
| Baldwin, Rt. Hon. Stanley | Crook, C. W. | Hope, Sir Harry (Forfar) |
| Balfour, George (Hampstead) | Crooke, J. Smedley (Deritend) | Hopkins, J. W. W. |
| Balniel, Lord | Crookshank, Col. C. de W. (Berwick) | Hopkinson, A. (Lancaster, Mossley) |
| Barclay-Harvey, C. M. | Crookshank, Cpt. H. (Lindsey, Gainsbro) | Hore-Belisha, Leslie |
| Barnett, Major Richard | Curzon, Captain Viscount | Howard, Capt. Hon. D. (Cumb., N.) |
| Beamish, Captain T. P. H. | Dalkeith, Earl of | Hudson, Capt. A. U. M. (Hackney, N.) |
| Beckett, Sir Gervase (Leeds, N.) | Davies, Maj. Geo. F. (Somerset, Yeovil) | Hudson, R. S. (Cumberl'nd, Whiteh'n) |
| Bellairs, Commander Carlyon W. | Dawson, Sir Philip | Hume-Williams, Sir W. Ellis |
| Benn, Captain Wedgwood (Leith) | Dean, Arthur Wellesley | Hurd, Percy A. |
| Berry, Sir George | Dixon, Captain Rt. Hon. Herbert | Hutchison, G. A. Clark (Midl'n & P'bl's) |
| Betterton, Henry B. | Drewe, C. | Hutchison, Sir Robert (Montrose) |
| Blades, Sir George Rowland | Eden, Captain Anthony | Jackson, Lieut.-Colonel Hon. F. S. |
| Boothby, R. J. G. | Edmondson, Major A. J. | Jackson, Sir H. (Wandsworth, Cen'l) |
| Bourne, Captain Robert Croft | Edwards, John H. (Accrington) | Jacob, A. E. |
| Bowater, Sir T. Vansittart | Elliot, Captain Walter E. | James, Lieut.-Colonel Hon. Cuthbert |
| Bowyer, Capt. G. E. W. | Ellis, R. G. | Jephcott, A. R. |
| Boyd-Carpenter, Major A | Elveden, Viscount | Jones, G. W. H. (Stoke Newington) |
| Brass, Captain W. | England, Colonel A. | Kennedy, A. R. (Preston). |
| Brassey, Sir Leonard | Erskine, James Malcolm Monteith | Kindersley, Major Guy M. |
| Briscoe, Richard George | Erskine, Lord (Somerset, Weston-s.-M.) | Kinloch-Cooke, Sir Clement |
| Brittain, Sir Harry | Evans, Captain A. (Cardiff, South) | Lamb, J. Q. |
| Brocklebank, C. E. R. | Evans, Capt. Ernest (Welsh Univer.) | Lane-Fox, Lieut.-Col. George R. |
| Brooke, Brigadier-General C. R. I. | Fairfax, Captain J. G. | Lister, Cunliffe-, Rt. Hon. Sir Philip |
| Broun-Lindsay, Major H. | Falle, Sir Bertram G. | Locker-Lampson, G. (Wood Green) |
| Brown, Brig.-Gen. H. C. (Berks, Newb'y) | Fanshawe, Commander G. D. | Locker-Lampson, Com. O. (Handsw'th) |
| Buckingham, Sir H. | Fermoy, Lord | Loder, J. de V. |
| Bull, Rt. Hon. Sir William James | Fielden, E. B. | Lougher, L. |
| Bullock, Captain M. | Fleming, D. P. | Lowe, Sir Francis William |
| Burgoyne, Lieut.-Colonel Sir Alan | Ford, P. J. | Luce, Maj.-Gen. Sir Richard Harman |
| Burman, J. B. | Forestier-Walker, L. | Lumley, L. R. |
| Burton, Colonel H. W. | Foster, Sir Harry S. | Macdonald, Capt. P. D. (I. of W.) |
| Butler, Sir Geoffrey | Fremantle, Lieut.-Colonel Francis E. | McDonnell, Colonel Hon. Angus |
| Cadogan, Major Hon. Edward | Ganzoni, Sir John | Macintyre, I. |
| Caine, Gordon Hall | Gillett, George M. | McLean, Major A. |
| Campbell, E. T. | Gilmour, Lt.-Col. Rt. Hon. Sir John | Macnaghten, Hon, Sir Malcolm |
| Cautley, Sir Henry S. | Goff, Sir Park | Maitland, Sir Arthur D. Steel- |
| Cayzer, Sir C. (Chester, City) | Grenfell, Edward C. (City of London) | Makins, Brigadier-General E. |
| Cayzer, Maj. Sir Herbt. R. (Prtsmth. S.) | Grotrian, H. Brent | Malone, Major P. B. |
| Cazalet, Captain Victor A. | Guinness, Rt. Hon. Walter E. | Manningham-Buller, Sir Mervyn |
| Cecil, Rt. Hon. Sir Evelyn (Aston) | Gunston, Captain D. W. | Margesson, Captain D. |
| Chadwick, Sir Robert Burton | Hacking, Captain Douglas H. | Marriott, Sir J. A. R. |
| Chamberlain, Rt. Hn. J. A. (Birm., W.) | Hall, Capt. W. D'A. (Brecon & Rad.) | Meyer, Sir Frank |
| Chamberlain, Rt. Hon. N. (Ladywood) | Hamilton, Sir R. (Orkney & Shetland) | Milne, J. S. Wardlaw- |
| Charteris, Brigadier-General J. | Hannon, Patrick Joseph Henry | Mitchell, Sir W. Lane (Streatham) |
| Christie, J. A. | Harney, E. A. | Molas, Thomas |
| Churchill, Rt. Hon. Winston Spencer | Harrison, G. J. C. | Mond, Rt. Hon. Sir Alfred |
| Churchman, Sir Arthur C. | Harvey, G. (Lambeth, Kennington) | Monsell, Eyres, Com. Rt. Hon. B. M. |
| Clarry, Reginald George | Harvey, Major S. E. (Devon, Totnes) | Moore, Lieut.-Colonel T. C. R. (Ayr) |
| Cobb, Sir Cyril | Haslam, Henry C. | Moore-Brabazon, Lieut.-Col. J. T. C. |
| Cochrane, Commander Hon. A. D. | Hawke, John Anthony | Morrison, H. (Wilts, Sallsbury) |
| Cockerill, Brigadier-General G. K. | Headlam, Lieut.-Colonel C. M. | Morrison-Bell, Sir Arthur Clive |
| Cohen, Major J. Brunel | Henderson, Lieut.-Col. V. L. (Bootle) | Murchison, C. K. |
| Colfox, Major Wm. Phillips | Heneage, Lieut.-Col. Arthur P. | Nelson, Sir Frank |
| Newman, Sir R. H. S. D. L. (Exeter) | Sanderson, Sir Frank | Thomson, Sir W. Mitchell-(Croydon, S.) |
| Nuttall, Ellis | Sandon, Lord | Tinne, J. A. |
| Oakley, T. | Sassoon, Sir Philip Albert Gustave D. | Tryon, Rt. Hon. George Clement |
| O'Neill, Major Rt. Hon. Hugh | Savery, S. S. | Trevelyan, Rt. Hon. C. P. |
| Oman, Sir Charles William C. | Scott, Sir Leslie (Liverp'l, Exchange) | Vaughan-Morgan, Col. K. p. |
| Ormsby-Gore, Hon. William | Shaw, Lt.-Col. A. D. Mcl. (Renfrew, W) | Wallace, Captain D. E. |
| Pennefather, Sir John | Shaw, Capt. W. W. (Wilts, Westb'y) | Ward, Lt.-Col. A. L. (Kingston-on-Hull) |
| Penny, Frederick George | Sheffield, Sir Berkeley | Warner, Brigadier-General W. W. |
| Percy, Lord Eustace (Hastings) | Simms, Dr. John M. (Co. Down) | Warrender, Sir Victor |
| Peto, Basil E. (Devon, Barnstaple) | Skelton, A. N. | Wells, S. R. |
| Pilditch, Sir Philip | Smith, R. W. (Aberd'n & Kinc'dine, C.) | White, Lieut.-Colonel G. Dairymple |
| Pownall, Lieut.-Colonel Assheton | Smith-Carington, Neville W. | Williams, Com. C. (Devon, Torquay) |
| Preston, William | Smithers, Waldron | Williams, Herbert G. (Reading) |
| Price, Major C. W. M. | Somerville, A. A. (Windsor) | Windsor-Clive, Lieut.-Colonel George |
| Rawlinson, Rt. Hon. John Fredk. Peel | Spender Clay, Colonel H. | Winterton, Rt. Hon. Earl |
| Rawson, Alfred Cooper | Sprot, Sir Alexander | Wise, Sir Fredric |
| Remnant, Sir James | Stanley, Col. Hon. G.F. (Will'sden, E.) | Wolmer, Viscount |
| Rentoul, G. S. | Stanley, Lord (Fylde) | Wood, B. C. (Somerset, Bridgwater) |
| Rhys, Hon. C. A. U. | Stanley, Hon. O. F. G. (Westm'eland) | Wood, Rt. Hon. E. (York, W. R., Ripon) |
| Rice, Sir Frederick | Stott, Lieut.-Colonel W. H. | Wood, E. (Chest'r, Stalyb'ge & Hyde) |
| Richardson, Sir P. W. (Sur'y, Ch'ts'y) | Strickland, Sir Gerald | Wood, Sir Kingsley (Woolwich, W.). |
| Roberts, Samuel (Hereford, Hereford) | Stuart, Crichton-, Lord C. | Wood, Sir S. Hill- (High Peak) |
| Ropner, Major L. | Stuart, Hon. J. (Moray and Nairn) | Woodcock, Colonel H. C. |
| Ruggles-Brise, Major E. A. | Sueter, Rear-Admiral Murray Fraser | Worthington-Evans, Rt. Hon. Sir L. |
| Russell, Alexander West (Tynemouth) | Sykes, Major-Gen. Sir Frederick H. | Young, E. Hilton (Norwich) |
| Rye, F. G. | Tasker, Major R. Inigo | |
| Samuel, A. M. (Surrey, Farnham) | Thompson, Luke (Sunderland) | TELLERS FOR THE AYES.— |
| Sandeman, A. Stewart | Thomson, F. C. (Aberdeen, South) | Colonel Gibbs and Major Sir Harry |
| Barnston. | ||
| NOES. | ||
| Adamson, W. M. (Staff., Cannock) | John, William (Rhondda, West) | Smith, Ben (Bermondsey, Rotherhithe) |
| Ammon, Charles George | Johnston, Thomas (Dundee) | Smith, H. B. Lees (Keighley) |
| Attlee, Clement Richard | Jones, Morgan (Caerphilly) | Smith, Rennie (Penistone) |
| Beckett, John (Gateshead) | Jones, T. I. Mardy (Pontypridd) | Snell, Harry |
| Charleton, H. C. | Kelly, W. T. | Snowden, Rt. Hon. Philip |
| Cluse, W. S. | Kennedy, T. | Stamford, T. w. |
| Cove, W. G. | Kenyon, Barnet | Stephen, Campbell |
| Dalton, Hugh | Lansbury, George | Thorne, G. R. (Wolverhampton, E.) |
| Day, Colonel Harry | Livingstone, A. M. | Thorne, W. (West Ham, Plaistow) |
| Duncan, C. | MacLaren, Andrew | Thurtle, E. |
| Gosling, Harry | Maclean, Nell (Glasgow, Govan) | Trevelyan, Rt. Hon. C. P. |
| Graham, D. M. (Lanark, Hamilton) | March, S. | Viant, S. P. |
| Graham, Rt. Hon. Wm. (Edin., Cent.) | Maxton, James | Watts-Morgan, Lt.-Col. D. (Rhondda) |
| Grenfell, D. R. (Glamorgan) | Montague, Frederick | Westwood, J. |
| Griffiths, T. (Monmouth, Pontypool) | Morris, R. H. | Wheatley, Rt. Hon. J. |
| Hall, F. (York, W. R., Normanton) | Morrison, R. C. (Tottenham, N.) | Williams, David (Swansea, East) |
| Hall, G. H. (Merthyr Tydvil) | Naylor, T. E. | Williams, T. (York, Don Valley) |
| Hardie, George D. | Oliver, George Harold | Windsor, Walter |
| Hayes, John Henry | Paling, W. | Wright, W. |
| Henderson, Rt. Hon. A. (Burnley) | Pethick-Lawrence, F. W. | Young, Robert (Lancaster, Newton) |
| Hirst, G. H. | Ponsonby, Arthur | |
| Hirst, W. (Bradford, South) | Potts, John S. | TELLERS FOR THE NOES.— |
| Hudson, J. H. (Huddersfield) | Scrymgeour, E. | Mr. T. Henderson and Mr. A. |
| Jenkins, W. (Glamorgan, Neath) | Shaw, Rt. Hon. Thomas (Preston) | Barnes. |
§ Clause read a Second time, and added to the Bill.
§ Mr. SPEAKERThe Clause standing next on the Order Paper—(Payment out of the New Sinking Fund (1923) of accruing interest on war saving certificates and national savings certificates)—cannot be taken, because it would involve a charge upon the, Consolidated Fund.
§ Mr. LEES-SMITHMay I point out that the object of this Clause is to remove a charge from the Consolidated Fund, and put it on to the Sinking Fund?
§ Mr. SPEAKERThe Sinking Fund is part of the Consolidated Fund. These things have always been considered to need a Resolution.
§ Mr. LEES-SMITHIt does not involve an increased charge, but merely takes a certain sum of money from one part of the Consolidated Fund to another part of the Consolidated Fund.
§ Mr. SPEAKERIt is not a charge in the sense of a new tax. If the hon. Member will look up the previous cases, I think he will find that we always have had a Resolution.