HC Deb 06 July 1949 vol 466 cc2245-57

Section eleven of the Customs and Inland Revenue Act, 1885 (which imposes a duty on the property of certain bodies corporate or unincorporate subject to the exemptions specified therein), shall be construed as if the reference to property belonging to a body corporate or unincorporate established for any trade or business included a reference to property belonging to a body corporate or unincorporate which carries on any trade or business the profits of which are liable to income tax or profits tax.—[Lieut.-Commander Braithwaite.]

Brought up, and read the First time.

Lieut.-Commander Braithwaite

I beg to move, "That the Clause be read a Second time."

During the Committee stage we put down an Amendment to Clause 26 covering the main point which I now desire to raise, but owing to the fact that the Committee fell behind an agreed time-table, it was arranged that this matter was to be raised upon the Report stage. During the passage of the Bill through Committee, we had two interesting discussions, one on football pools and another on football professionals and their benefits. This new Clause will to some extent cover the financial position of football clubs and indeed sporting clubs as such.

The object which we have here is to exempt from Corporation Duty the property of any body which is liable for Profits Tax. It was that point which we should have raised on the Committee stage had the opportunity then arisen. There are many sporting clubs and associations which at the present time find themselves, under our present system of taxation, liable both for Profits Tax and Corporation Duty. The point is perhaps slightly technical but is briefly as follows. If their funds are invested, they find that the Inland Revenue authorities charge Profits Tax on income therefrom where it has reached a sufficient height under Section 32 of the Finance Act, 1947; but such investment income, including that from any property the club may hold, is also subject to Corporation Duty at 5s. under the Customs and Inland Revenue Act, 1885. The exemption given under Section 11 (5) of that Act to bodies established for conducting a business is at present very narrowly applied by the Inland Revenue, and is given only where there is proof that the body in question had been originally set up for the conduct of a business.

8.0 p.m.

The difficulty which arises is this. It is hardly ever possible for sports clubs to prove, although they are treated as an industry or business for tax purposes, that they get charged Profits Tax as well; and so, on an income from investments and other property, sports clubs have to pay a Corporation Duty and Profits Tax, subject of course to abatement, and they also come in for Income Tax on the standard rates as reduced by the Profits Tax paid. I wish to suggest to the House that it is clearly inequitable to charge these clubs Profits Tax as business concerns, while at the same time charging them Corporation Duty as non-business concerns. That is the gravamen, of our complaint as set forth in this new Clause.

While I am placing this argument before the House, perhaps I may refer to the curious effect of Income Tax on a number of these clubs. I have before me an example of a football club of which I have had the honour to be vice-president for a good many years, the Barnet Club, a noted amateur club which plays in the Athenian League. I understand that they have been in touch with their Member, whom I hoped to see in his place to give me his support. I have here figures which go back for 18 years. I will not read them to the House because it is a very long list, but I will send the list to the right hon. and learned Gentleman because I think he will find it illuminating as the sort of thing which is liable to happen to football clubs. From the financial year 1931–32 up to now, this club has on four occasions only, finished on the right side and made a profit. It so happens that the two occasions when the profit has been substantial have both fallen in this post-war period, the reason being that on these two occasions the club managed to get as far as the final tie of the Amateur Cup played before about 50,000 spectators at Stamford Bridge, Chelsea. They got a high rake-off of £963 in the 1945–46 season and £908 in the 1947–48 season.

After long years of playing these competitions, they have at last managed twice within three years to make a substantial profit, but it so happens that they have had the misfortune to make it when Income Tax is standing at the high level of today. Football clubs, when they are confronted with Income Tax demands, cannot of course claim allowances. They have no wives or children, and certainly they have no unrelated beneficiaries, a subject we were discussing the other day. What they seek to do, when they find themselves in this fortunate position of having more money coming in as a result of their success on the playing fields, is to put that money to ground improvements of one kind or another. Amateur clubs have no paid officials, with the exception of a groundsman to look after the pitch. None of their officials or players participate in these profits, and it is a little unfortunate at a time when Income Tax falls so heavily on them that there should be this anomaly which I have endeavoured to outline to the House.

I hope the Solicitor-General will feel that there is here a real case for sympathetic review. In a way, I think it is unfortunate that the time-table on the Committee stage got into such a position that we could not raise this matter then, because I have the feeling that if we could have deployed the argument then, it would have been looked into and on Report stage the Government might have been able to meet us. Instead, they are confronted for the first time with the case I have endeavoured to put forward, I am afraid inadequately, although some of my hon. Friends will be speaking later on the new Clause. I suggest that here is a matter that might engage the attention of the right hon. and learned Gentleman.

Mr. Erroll

I beg to second the Motion so admirably moved by my hon. and gallant Friend the Member for Holderness (Lieut.-Commander Braithwaite).

I am quite sure that when the Corporation Duty was originally introduced in the 19th century, it was never envisaged there would later on be a Profits Tax which could be levied as well. It seems quite obvious that this anomaly, and it can be no more than an unintentional anomaly—should not be allowed to hamstring, not those who normally make large profits, but a worthwhile group of institutions because they are successful in the financial management of their affairs, a group of institutions which everybody concedes are playing a useful part in our national life. It seems particularly unfortunate that these clubs and sporting institutions should find they are liable to this supernumerary tax which represents a small additional burden that is inequitable, to say the least.

The position is really made worse by the narrow interpretation placed by the Inland Revenue on what constitutes a business for the purposes of obtaining exemption from Corporation Duty. I understand that all businesses within the narrow definition may claim exemptions from Corporation Duty, but that a body desirous of coming within the scope of that definition has to show that it was originally founded for the express purpose of carrying on a business and has done so ever since, whereas most sporting clubs, although they may be run on sound business lines, were not for the main part originally brought into being solely for the purpose of carrying on a business out of their sporting activities, and therefore fail to qualify for an exemption.

If the Chancellor of the Exchequer cannot see his way to accept this new Clause, I hope it will be possible for him to instruct the Inland Revenue to work to a wider definition of a business and thus afford a relief which is very much needed. It would not be a very expensive relief for the Treasury, but it would remove an anomaly which I am sure was never intended when the original legislation was introduced.

The Solicitor-General

I cannot help thinking that this new Clause has been moved under a misapprehension of the true purposes of the nature of the Corporation Duty. The hon. and gallant Member for Holderness (Lieut.-Commander Braithwaite), in propounding his argument, said there was an anomaly in that a football club was taxed to Profits Tax as a trading concern carrying on a business and at the same time to Corporation Duty on the basis that it was a non-trading concern. This tax, as the hon. and gallant Gentleman told the House, was imposed by Section 11 of the Customs and Inland Revenue Act, 1885, for a specific purpose—to compensate the Exchequer in cases where property held by corporations and unincorporated bodies could not be liable to Estate Duty on the basis that it was not owned by individuals who could die. The purpose of the tax was to compensate the Exchequer for not getting Estate Duty on the property owned by such corporations.

A corporation whose capital is not divided into shares, such as a City Livery company, obviously can never suffer Estate Duty upon its property, whereas a company which is owned in shares has shareholders and when they die, their shareholdings pass as part of their estate and accordingly become liable to Estate Duty and to Succession or Legacy Duty. Therefore, inasmuch as the Exchequer could never obtain Estate Duty upon the property of corporations whose capital was not divided into shares, this tax was imposed in 1885. If I may quote the actual words used in Section 11, hon. Members will see that the specific and express purpose of the legislature was to compensate the Exchequer in that way. These are the words: Whereas certain property, by reason of the same belonging to or being vested in bodies corporate or unincorporate, escapes liability to probate, legacy, or succession duties, and it is expedient to impose a duty thereon by way of compensation to the revenue. And then it proceeds to impose the duty.

Section 11 also contains certain specific exemptions designed to take out of the scope of the tax the property of corporations in respect of which Estate Duty could become chargeable. Therefore, if one looks at the relevant exemption for the purpose of this new Clause, subsection (5), one finds that the following is exempted from the scope of the tax: Property belonging to or constituting the capital of a body corporate or unincorporate established for any trade or business, or being the property of a body whose capital stock is so divided and held as to be liable to be charged to legacy duty or succession duty. Therefore, the purpose of the exemption is to take out of the scope of the tax trading corporations whose capital is held in stocks and shares in such a way that it is owned by individuals who can die, and upon whose estates duty will be charged, including that part of their estate which consists of the shares of those corporations.

In the case of the clubs mentioned by the hon. and gallant Gentleman, they do not come within that exemption because their property is held by corporations in respect of which Estate Duty can never be charged. Therefore, prima facie, there is no reason why they should come out of the scope of the Corporation Duty. The mere fact that incidentally they carry on some trade, or indeed a substantial trade, does not take them outside the scope of the tax unless they are clubs whose property can become subject to Estate Duty because it is owned by shareholders, that is, persons who have individual interests in the property of the company. So, in principle, there is no reason why this Clause should be accepted.

Corporation Duty is in no sense a substitute for, or an addition to, a tax on trading profits. It is not a tax on trading profits at all. It is a tax of 5 per cent.—the same rate as was fixed in 1885—charged upon the income from property belonging to these companies. It does not fall upon trading receipts as such, but simply upon the investment income which they derive from property. That being so, where there is a club which is not established for trading—that was the expression used in the Act of 1885 to describe joint stock companies—and whose capital is not divided into shares, it comes plumb within the scope of the tax, and it should not be taken out of the tax because it carries on some trade and earns some trading receipts. The Profits Tax is a tax upon its trading receipts whereas this is a quite different tax charged on the investment income arising from the annual value of its property. If these clubs are taken out of the scope of the tax, the Revenue will not be compensated for the fact that the property of these clubs can never become subject to Estate Duty or to Legacy or Succession Duty. That is why, when I began my argument, I submitted that hon. Members opposite were under a misapprehension as to the nature and purpose of this tax, which is not an additional tax on trade—

8.15 p.m.

Mr. Selwyn Lloyd


The Solicitor-General

I will give way in a moment. There is no logical reason at all why an exception should be made in the case of these clubs when there is no principle according to which, in relation to the context of the taxation legislation, it could possibly be justified.

Mr. Selwyn Lloyd

I am trying to follow the argument of the right hon. and learned Gentleman. Would he be good enough to repeat what he said about exemptions, because I did not quite catch it.

The Solicitor-General

I am sorry if I did not make it clear. There are a series of exemptions in Section 11 of the 1885 Act, and Subsection (5) takes out of the scope of Section 11 corporations whose capital is divided into shares, with the result that the shares can be held by individuals and, when those individuals die, Estate Duty—or as was then the case, Legacy or Succession Duty—was charged upon the individual holdings of the shareholders of those companies. The companies which are excluded are joint stock companies, that is, companies whose capital is divided into shares and, accordingly, can be held by individuals whose shareholdings on their death become liable to Estate Duty.

If the Clause is accepted, it means that for no justifiable reason in principle these clubs are taken out of the scope of the tax, no compensating charge is made, and the Revenue is simply faced with a loss, which is utterly unjustifiable having regard to the general purpose of the tax. For that reason, I ask the House to say that no case has been made out for excluding these clubs from the ambit of the tax.

Colonel J. R. H. Hutchison (Glasgow, Central)

May I add my voice in an appeal, even at this late hour, that something should be done in cases of this kind? The House is always rightly suspicious of any suspected case of double taxation, and in spite of what the right hon. and learned Gentleman has said, I still believe that this is a case of double taxation. We are dealing, not with a rapacious, profit-earning concern, but merely with one which is striving over a period to make ends meet.

The right hon. and learned Gentleman based his justification for the continuation of this Corporation Duty on the fact that no Estate Duty would become payable from an organisation of this kind. I speak subject to correction, and would like to learn from the right hon. and learned Gentleman if I am wrong. Is it not the case that under the Bill the Estate, Succession and Legacy Duties are being altered? Under the alterations which are to take place, can it still be contended that this kind of organisation would, under the Bill, still be liable to Estate Duty? If it would not still be liable to Estate Duty—this compensating duty which, the right hon. and learned Gentleman says, is a justification for its existence—then his argument falls to the ground.

The Solicitor-General

Perhaps I should have made that clear. I read out the provisions dealing with exemption, which finished with these words: whose capital stock is so divided and held as to be liable to be charged to legacy duty or succession duty. The whole purpose of the Clause which deals with Corporation Duty—Clause 27—is to make consequential amendments by reason of the fact that we are including Legacy and Succession duty in Estate Duty. It does not alter the law in that sense. It simply makes the necessary amendments in the law, because we can no longer refer back to the words as to be liable to be charged to legacy duty or succession duty … since they are no longer applicable.

Colonel Hutchison

May I put this specific point to the right hon. and learned Gentleman? I am trying to follow whether his argument is in any way invalidated by the Bill as it is proposed it shall emerge. Do I understand him to say that a sporting club of the kind we are considering will be just as liable for Estate Duty under the Bill as it emerges as it was in the past, or is there any change in the position which would have obtained?

The Solicitor-General

The difficulty is that a sporting club such as has been described was not previously liable to Legacy or Succession Duty; that is to say, its property could not be liable to Succession or Legacy Duty in the event of a particular person dying; and no more can it be liable to Estate Duty. Therefore, its situation as far as liability to Estate Duty and Legacy and Succession Duty is concerned is exactly the same.

Colonel Hutchison

I am sorry I did not express the point clearly. What I meant to say was this. If Succession and Legacy Duty are disappearing all round an organisation of this kind, then the justification for compensating the Treasury because this particular organisation was not liable, while everything surrounding it was liable, for Succession and Legacy Duty might have some validity; but if Legacy and Succession Duty are being incorporated in Estate Duty, and all the surrounding and comparable concerns are now having their position altered, then the justification for Corporation Duty on the sporting clubs no longer remains.

If I am wrong, then surely the incidence of Profits Tax was never intended to refer to a concern which is not a profit-making concern or, at any rate, not a profit-distributing concern; and the reserves for the future which it is necessary for an organisation of this kind to provide should not, surely, be liable to the 10 per cent. undistributed Profits Tax. Whether a justification can be found for one of these taxes or for the other, there is no justification for both at the same time.

Question put, "That the Clause be read a Second time."

The House divided: Ayes, 117; Noes, 251.

Division No. 201.] AYES [8.25 p.m.
Agnew, Cmdr. P. G. Fraser, Sir I. (Lonsdale) Low, A. R. W.
Amory, D. Heathcoat Fyfe, Rt. Hon. Sir D. P. M. MacAndrew, Col. Sir C.
Assheton, Rt. Hon. R. Galbraith, Cmdr. T. D. (Pollok) McCorquodale, Rt. Hon. M. S.
Astor, Hon. M. Galbraith, T. G. D. (Hillhead) McFarlane, C. S.
Barlow, Sir J. Gammans, L. D. Mackeson, Brig. H. R.
Beamish, Maj. T. V. H. Gomme-Duncan, Col. A. Maclay, Hon. J. S.
Bennett, Sir P. Granville, E. (Eye) MacLeod, J.
Boles, Lt.-Col. D. C. (Wells) Grimston, R. V. Macmillan, Rt. Hon. Harold (Bromley)
Bower, N. Hannon, Sir P. (Moseley) Macpherson, N. (Dumfries)
Braithwaite, Lt.-Comdr. J. G. Harris, F. W. (Croydon, N.) Maitland, Comdr. J. W.
Brown., W. J. (Rugby) Harris, H. Wilson (Cambridge Univ.) Manningham-Buller, R. E.
Buchan-Hepburn, P. G. T. Harvey, Air-Comdre. A. V. Marlowe, A. A. H.
Butler, Rt. Hn. R. A. (S'ffr'n W'ld'n) Headlam, Lieut.-Col. Rt. Hon. Sir C. Marples, A. E.
Carson, E. Henderson, John (Cathcart) Marsden, Capt. A.
Channon, H. Hinchingbrooke, Viscount Marshall, D. (Bodmin)
Clarke, Col. R. S. Hogg, Hon. Q. Medlicott, Brigadier F.
Crookshank, Capt. Rt. Hon. H. F. C. Holmes, Sir J. Stanley (Harwich) Mellor, Sir J.
Crosthwaite-Eyre, Col. O. E. Hope, Lord J. Morrison, Maj. J. G. (Salisbury)
Cuthbert, W. N. Hulbert, Wing-Cdr. N. J. Morrison, Rt. Hon. W. S. (Cirencester)
Darling, Sir W. Y. Hutchison, Lt-Cdr. Clark (Edin'gh, W.) Mott-Radclyffe, C. E.
Davidson, Viscountess Hutchison, Col. J. R. (Glasgow, C.) Neill, W. F. (Belfast, N.)
De la Bère, R. Jeffreys, General Sir G. Nield, B. (Chester)
Digby, Simon Wingfield Jennings, R. Noble, Comdr. A. H. P.
Dodds-Parker, A. D. Joynson-Hicks, Hon. L. W. Odey, G. W.
Dower, E. L. G. (Caithness) Keeling, E. H. Peto, Brig. C. H. M.
Duthie, W. S. Kerr, Sir J. Graham Ponsonby, Col. C. E.
Eccles, D. M. Lambert, Hon. G. Price-White, Lt.-Col. D.
Eden, Rt. Hon. A. Lancaster, Col. C. G. Raikes, H. V.
Erroll, F. J. Legge-Bourke, Maj. E. A. H. Rayner, Brig. R.
Fletcher, W. (Bury) Lennox-Boyd, A. T. Renton, D.
Fox, Sir G. Lipson, D. L. Roberts, H. (Handsworth)
Fraser. H. C. P. (Stone) Lloyd, Selwyn (Wirral) Ross, Sir R. D. (Londonderry)
Sanderson, Sir F. Sutcliffe, H. Wheatley, Colonel M. [...] (Dorset. E.)
Shephard, S. (Newark) Thorneycroft, G. E. P. (Monmouth) White, Sir D. (Fareham)
Smith, E. P. (Ashford) Thorp, Brigadier R. A. F. Williams, C. (Torquay)
Spearman, A. C. M. Touche, G. C. Williams, Gerald (Tonbridge)
Spence, H. R. Wakefield, Sir W. W. Young, Sir A. S. L. (Partick)
Stoddart-Scott, Col. M. Walker-Smith, D.
Strauss, Henry (English Universities) Watt, Sir G. S. Harvie TELLERS FOR THE AYES:
Studholme, H. G. Webbe, Sir H. (Abbey) Mr. Drewe and Major Conant.
Adams, Richard (Balham) Fairhurst, F. Maclean, N. (Govan)
Alexander, Rt. Hon. A. V. Farthing, W. J. McLeavy, F.
Allen, A. C. (Bosworth) Fernyhough, E. MacMillan, M. K. (Western Isles)
Allen, Scholefield (Crewe) Field, Capt. W. J. MacPherson, Malcolm (Stirling)
Alpass, J. H. Fletcher, E. G. M. (Islington, E.) Macpherson, T. (Romford)
Anderson, A. (Motherwell) Follick, M. Mainwaring, W. H.
Attewell, H. C. Foot, M. M. Mallalieu, E. L. (Brigg)
Austin, H. Lewis Forman, J. C. Mallalieu, J. P. W. (Huddersfield)
Awbery, S. S. Fraser, T. (Hamilton) Mann., Mrs. J.
Ayles, W. H. Freeman, J. (Watford) Manning, Mrs. L. (Epping)
Bacon, Miss A. Gallacher, W. Mathers, Rt. Hon George
Baird, J. Ganley, Mrs. C. S. Mellish, R. J.
Balfour, A. Gibbins, J. Messer, F.
Barnes, Rt. Hon. A. J. Gitzean, A. Middleton, Mrs. L.
Barstow, P. G. Glanville, J. E. (Consett) Mitchison, G. R.
Barton, C. Grenfell, D. R. Monslow, W.
Battley J. R. Gray, C. F. Moody, A. S.
Bechervaise, A. E. Grierson, E. Morley, R.
Benson, G. Griffiths, Rt. Hon. J. (Llanelly) Nally, W.
Berry, H. Guest, Dr. L. Haden Naylor, T. E.
Bing, G. H. C. Gunter, R. J. Nichol, Mrs. M. E. (Bradford, N.)
Binns, J. Guy, W. H. Nicholls, H. R. (Stratford)
Blackburn, A. R. Hale, Leslie Noel-Buxton, Lady
Blenkinsop, A. Hall, Rt. Hon. Glenvil Oldfield, W. H.
Blyton, W. R. Hamilton, Lieut.-Col. R. Oliver, G. H.
Boardman, H. Hannan, W. (Maryhill) Orbach, M.
Bottomley, A. G. Harrison, J. Paget, R. T.
Bowden, Fig. Offr. H. W. Hastings, Dr. Somerville Paling, Will T. (Dewsbury)
Brook, D. (Halifax) Haworth, J. Palmer, A. M. F.
Brooks, T. J. (Rothwell) Henderson, Joseph (Ardwick) Pargiter, G. A.
Broughton, Dr. A. D. D. Herbison, Miss M. Parker, J.
Brown, T. J. (Ince) Holmes, H. E. (Hemsworth) Parkin, B. T.
Bruce, Maj. D. W. T. Horabin, T. L. Paton, Mrs. F. (Rushcliffe)
Burden, T. W. Houghton, A. L. N. D. (Sowerby) Paton, J. (Norwich)
Burke, W. A. Hoy, J. Pearson, A.
Butler, H. W. (Hackney, S.) Hubbard, T. Popplewell, E.
Callaghan, James Hudson, J. H. (Ealing, W.) Porter, E. (Warrington)
Carmichael, James Hughes, Emrys (S. Ayr) Porter, G. (Leeds)
Champion, A. J. Hughes, Hector (Aberdeen, N.) Price, M. Philips
Chetwynd, G. R. Hughes, H. D. (W'lverh'pton, W.) Pritt, D. N.
Cluse, W. S. Hynd, H. (Hackney, C.) Proctor, W. T.
Cobb, F. A. Irvine, A. J. (Liverpool) Pryde, D. J.
Cocks, F. S. Isaacs, Rt. Hon. G. A. Randall, H. E.
Coldrick, W. Janner, B. Ranger, J.
Collick, P. Jay, D. P. T. Rankin, J.
Collins, V. J. Jeger, G. (Winchester) Reid, T. (Swindon)
Colman, Miss G. M. Jeger, Dr. S. W. (St. Pancras, S. E.) Rhodes, H.
Cook, T. F. Jenkins, R. H. Richards, R.
Corlett, Dr. J. Jones, D. T. (Hartlepool) Robinson, Kenneth (St. Pancras, N.)
Cove, W. G. Jones, Elwyn (Plaistow) Ross, William (Kilmarnock)
Cripps, Rt. Hon. Sir S. Jones, J. H. (Bolton) Royle, C.
Cullen, Mrs. Keenan, W. Sargood, R.
Daggar, G. Kenyon, C. Scollan, T.
Daines, P. Key, Rt. Hon C. W. Scott-Elliot, W.
Dalton, Rt. Hon. H. King, E. M. Shackleton, E. A. A.
Davies, Edward (Burslem) Kinley, J. Sharp, Granville
Davies, Haydn (St. Pancras, S. W.) Kirby, B. V. Shawcross, Rt. Hn. Sir H. (St. Helens)
Davies, R. J. (Westhoughton) Lang, G. Shurmer, P.
Deer, G. Lavers, S. Silverman, J. (Erdington)
de Freitas, Geoffrey Lee, F. (Hulme) Simmons, C. J.
Diamond, J. Leslie, J. R. Smith, C. (Colchester)
Dobbie, W. Lewis, T. (Southampton) Smith, H. N. (Nottingham, S.)
Dodds, N. N. Lindgren, G. S. Smith, S. H. (Hull, S. W.)
Donovan, T. Lipton, Lt.-Col. M. Snow, J. W.
Driberg, T. E. N. Longden, F. Sorensen, R. W.
Dugdale, J. (W. Bromwich) Lyne, A. W. Soskice, Rt. Hon Sir Frank
Dye, S. McAdam, W. Sparks, J. A.
Ede, Rt. Hon. J. C. McAllister, G. Steele, T.
Edelman, M. McEntee, V. La T. Stubbs, A. E.
Edwards, John (Blackburn) McGhee, H. G. Swingler, S.
Edwards, Rt. Hon. N. (Caerphilly) McGovern, J. Symonds, A. L.
Evans, John (Ogmore) Mack, J. D. Taylor, H. B. (Mansfield)
Evans, S. N. (Wednesbury) McKay, J. (Wallsend) Taylor, R. J. (Morpeth)
Ewart, R. McKinlay, A. S. Thomas, D. E. (Aberdare)
Timmons, J. Webb, M. (Bradford, C.) Williams, W. R. (Heston)
Titterington, M. F. Wells, P. L. (Faversham) Willis, E.
Tolley, L. Wells, W. T. (Walsall) Wills, Mrs. E. A.
Tomlinson, Rt. Hon. G. Wheatley, Rt. Hon. John (Edin'gh, E.) Woodburn, Rt. Hon. A.
Usborne, Henry White, H. (Derbyshire, N. E.) Woods, G. S.
Walker, G. H. Whiteley, Rt. Hon. W. Yates, V. F.
Wallace, G. D. (Chislehurst) Willey, F. T. (Sunderland) Young, Sir R. (Newton)
Wallace, H. W. (Walthamstow, E.) Williams, D. J. (Neath)
Warbey, W. N. Williams, J. L. (Kelvingrove) TELLERS FOR THE NOES:
Watkins, T. E. Williams, Ronald (Wigan) Mr. Collindridge and
Watson, W. M. Williams, W. T. (Hammersmith, S.) Mr. Wilkins.

Question put, and agreed to.