HC Deb 28 June 1951 vol 489 cc1696-715

Section forty-one of the Finance Act, 1950, shall be repealed and replaced by the following: (1) Where, as respects any tax carrying interest under section eight of the Finance (No. 2) Act, 1947—

  1. (a) the tax is in respect of profits or income arising in a country outside the United Kingdom; and
  2. (b) it is impossible by reason of the necessary foreign exchange not being available, for the profits or income to be remitted to the United Kingdom, or
  3. (c) the Commissioners of Inland Revenue are satisfied, having regard to the rate of exchange available, that it is reasonable that the profits should not be remitted for the time being to the United Kingdom,
the Commissioners of Inland Revenue shall allow the tax to remain uncollected. (2) Interest on the said tax shall, subject to the provisions of subsection (3) of this section, cease to run under the said section eight as from the date on which subsection (1) of this section applies and, if the said date is not later than three months from the time when the tax became due and payable, the interest thereon under the said section eight in respect of the period before the said date shall he remitted. (3) Where, under subsection (2) of this section, interest has ceased to run on any tax and thereafter subsection (1) of this section ceases to apply in whole or in part and demand is made by the collector or other proper officer for payment of all or any of that tax, interest under the said section eight shall again begin to run from the date of the demand in respect of the amount demanded: Provided that where all or any part of the amount demanded is paid not later than three months from the date of the demand, the interest under the said section eight on the amount so paid running from the date of the demand shall be remitted. (4) This section shall apply in relation to all assessments made whether before or after the passing of this Act, and, in relation to any assessment made before the passing of this Act, shall be deemed always to have had effect."—[Mr. Eccles.]

Brought up, and read the First time.

Mr. Eccles

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

The tax to which the proposed new Clause relates is in respect of either income or profits arising in countries outside the United Kingdom, in cases where, through no fault of the taxpayer, that money cannot be converted into sterling. A fairly simple principle is behind this proposal. It is the question whether a man ought to have to pay tax on income until he has got that money in his own hands.

We have argued this case for many years running. Last year we got a small concession from the Government, and it was embodied in Section 41 of the Finance Act, 1950. I will put it shortly to save time. The effect of last year's change was that no taxpayer is asked to pay his tax on foreign money which he cannot remit, or to pay any interest while he is waiting until he can remit it, provided that two conditions are fulfilled. The first is that the failure to remit results from an action of a foreign Government, and the second condition is that the Commissioners are of the opinion, even where the first condition is fulfilled and the foreign Government has clamped with an exchange control with the result that the man cannot get his money out, that it will not hurt him to pay out of some other income which he possesses.

My hon. Friends on this side of the House made it clear a year ago that we did not think that those two conditions were fair or would work out well in practice. Nevertheless, we accepted the concession, for we would have a year and would see what happened. We have had the year, and we think we are amply justified by results in the objections that we put forward last year. That is why I am moving the new Clause, which is intended to be in substitution for Section 41 of last year's Finance Act.

These are the changes, put briefly, which are made by our proposed Clause. We seek to omit the restricting words as the result of action of the [foreign] government, etc. Of course, the foreign Government is the main offender, but in the great majority of cases the reason the taxpayer cannot bring his money to this country is that the foreign Government have some exchange control which prohibits the transfer of profits.

9.0 p.m.

If that is the case, the only remedy is in the hands of His Majesty's Government. It is for His Majesty's Government to go to the other party and say, "You, by your exchange control, are keeping British money in the Argentine," or Spain, or wherever it is, "and we desire to negotiate with you a trade and payments agreement under which provisions are made for this kind of transfer to be permitted." A private person cannot make such an agreement with a foreign Government, and, if the Treasury fail to make that kind of agreement, the onus is on the Treasury, and it is then unjust for the Treasury to say to the British taxpayer, "Although we have failed to make this agreement with the foreign Government—and it is our business to do that—none theless you must pay the tax although you have not the money with which to pay it." From that point of view, I ask the House to say that this is a very grave injustice, because exchange controls are intergovernmental business.

All the same, we find that there are cases where transfer is impossible. There may be a nominal free market in the currency concerned, but when we go to buy sterling there may be no sterling to buy. That is regrettable, but it happens. We feel that it is, therefore, not fair to include the normal man who is prevented because of exchange control from transferring money and to exclude the man who happens to be dealing in a country where they have no exchange control—they may not have civil servants capable of working one—and there is no sterling to buy even if one wishes to do so.

The second change we make is to insert subsection (1, c) to cover the case where it is possible to transfer the foreign currency but only at a blackmail rate. There are countries which establish a number of different rates and which sometimes say to the British owner of their own currency, "If you accept an absolutely knock-out rate you can get the money out." It is very hard if the Treasury assess the liability to tax upon the official rate when the wretched man can only get his money out at a rate far below that and when, just because he can get the money out at that rate, the Commissioners say, "You can make the transfer and therefore you must pay the tax."

I want to put to the right hon. Gentleman a point which has not been made in previous debates. It relates to a case where a man owns a deposit in a foreign country, which he may have received by way of profits or income, and it is blocked. The Treasury say, "You are liable to tax at the official rate supposing you can transfer it." What really is the value of a foreign currency which one cannot transfer? I do not think it has any value at all in sterling. As long as money is blocked in a certain country and it is impossible to bring it into one's own country, it is highly arbitrary to fix a sterling value for it, because by the time one may be allowed to transfer the money the rate may have altered altogether.

There are big changes in rates of exchange, and that is one of the reasons the present law is grossly unfair. We have seen it in the case of the Argentine, which is one of the chief offenders in this respect. A man may have earned £10,000 in a foreign country in 1947 and may not have been allowed to bring it out until now. It may be that the exchange rates have changed and that the £10,000 is now worth only £5,000. It is very unjust that such a man should have to pay tax on the £10,000. That is the kind of thing that happens under the present law.

Our third change—an important one in my judgment—is to omit paragraph (c) of Section 41. If I may be allowed to read that paragraph, it says that the Commissioners can postpone the payment of the tax if … having regard to the matters aforesaid and to all the other circumstances of the case it is reasonable that the tax should for the time being remain uncollected. How have the Commissioners interpreted that? They have said that the meaning of "having regard to … all the other circumstances of the case "is having regard to how much income or reserves the company may have outside that which is blocked in the foreign country. We get cases where companies have large liabilities in respect of frozen profits in the Argentine and a certain amount of income from another country, and they are made to pay tax out of the other income simply because they have some cash.

We made it clear a year ago on this side of the House that we do not believe that is a sound principle. It should not depend upon whether or not a company has any other source of income that the Commissioners say the company must pay tax on money which they cannot collect. Sometimes that works very hardly. I will give only an imaginary case because it is rather hard on companies to give actual cases if they are in negotiation with the Governments concerned. For example, the House will know that many companies started as pastoral companies in the Argentine and, after a while, found that conditions there were not very satisfactory and they decided to have a branch in, say, Australia. Quite a number of companies are in that position. Whatever profits they make in the Argentine are blocked and cannot be transferred. If they are struggling in Australia to build up meat production, needing every penny they can get to expand their operations in that country, whatever income they may get from Australia has not only to bear the tax on their profits in Australia but out of that income they must also pay the tax on their Argentine business. That is having a bad effect on expansion in places where this House wants companies to expand.

I know the stock Treasury objection to a Clause of the type I am speaking to. It is that it would encourage firms to leave money abroad and thereby avoid tax. There is nothing in that objection, because under our Clause the Commissioners can only agree that the tax remains uncollected if the company or person can show that they have tried all the available means of transferring the money. In 99 cases out of 100 the obstacle to transferring the money will be the exchange control in the foreign country.

Who knows about exchange controls? The Treasury know more about them than anyone else, and I do not think anyone could bluff the Treasury that he was unable to get money through an exchange control when it was quite simple to do so. Therefore, I think the matter is in the hands of the Government. The Attorney-General objected last year that the result of what we believe to be a just provision would be that all sorts of people would leave their money abroad and not bring it home. That objection does not flatter the Treasury, who are perfectly capable of knowing whether there is an opportunity for a man to bring his money home or not.

I would not mind a little pressure put upon the Treasury to be a bit tougher with some foreign Governments in their arrangements about clearing agreements, and so on. If the Treasury knew that they would collect some tax if they made a good agreement, I am not at all sure that they would not go to it with a little more enthusiasm than they sometimes do. I think they are very good and able, and I must even confess that I have made a clearing agreement myself with the Government in the old days. A little inducement does no one any harm, and I should like to see it that way round. I should like to see more pressure to free the exchanges. Therefore, I am not in the least afraid of the consequences of doing justice to those who cannot transfer their money or those who might be tempted to hold their money abroad a little longer.

My final word is this. We really must reverse the trend in this Bill, which is to penalise British people doing business overseas. That simply will not do. We have had one Clause after another which will make it less attractive to conduct foreign business from the United Kingdom than from another capital city in the world. That cannot but do harm to our country.

Here is just one more of so many instances we have had where the result of the present law must be to make those who are going to launch out abroad say, "I do not think I will go into the difficult areas of the world. I will not go into the places where exchange is difficult. I will stick to the old-established markets." That is not in the interests of a country like ours, which has to pay for its imports somehow, wherever they come from. Any goods we can sell anywhere, and for which we finally get paid, assist us to buy our food and raw materials. We cannot be choosey about the markets in which we sell—we have to sell all over the world.

The kind of Clause that we have put down is merely a stimulant to people to launch out and not to be afraid to take risks. If that were agreed by the Chancellor as being the effect of the Clause. I would hope that he would accept it.

Mr. Studholme (Tavistock)

I beg to second the Motion so ably and comprehensively moved by my hon. Friend the Member for Chippenham (Mr. Eccles). I do not propose to cover the ground which he has covered, because I am not a financial expert, and I only wish to give by way of illustration the very unfair effect upon companies and individuals of the present law with regard to profits unremitted by reason of exchange restrictions. I must declare a personal interest, because I happen to be a director of a small private company which operates in the Argentine.

Since 1947, it has been quite impossible for us to get any money over to this country on account of profits, income, capital or anything else— not a penny—because of the Argentine exchange restrictions. Nevertheless, until this year we have been obliged to pay many thousands of pounds, in spite of annual protests, in Income Tax and Profits Tax on the profits arising to us in the Argentine, which we cannot get over to this country, however hard we try.

We have had to pay taxes out of income on which the company has already paid tax in this country. The directors very prudently put that income aside in order to pay out of it the very modest office expenses which we incur in the year, and to enable them, as they hoped, to be able to continue to pay a small dividend to the shareholders in this country. What sticks in my throat is that we have been asked to pay tax, out of money which has already once been taxed in this country, to meet taxes on income and profits arising in another country, which we cannot get over to this country through no fault of our own. I can honestly say that I feel very bitter about it.

9.15 p.m.

Every year we protested before making this payment. Last year I wrote to the Financial Secretary, and I received a very polite but quite unsympathetic reply. Obviously he was merely quoting what he had been told by the Treasury. This year, after I had written to the Chancellor, I received an intimation from the Revenue that they had kindly consented to hold in abeyance any further demand. I imagine the reason was because I had pointed out to them that if we paid the full amount of tax which they demanded we should have nothing left in this country to meet our very modest office expenses for the next year or two.

We have paid no dividend at all for the last two years, nor have the directors received any remuneration for some time. The fact that we have paid no dividend has been a considerable hardship to at least one old lady of over 80, who is dependent partly on this income from the Argentine. I know that some Members opposite consider that people of the rentier class are the lowest form of life—

Mr. Kirkwood (Dumbartonshire, East)

No they do not.

Mr. Studhohne

I am glad to hear the right hon. Gentleman say that. These unfortunate people have, owing to saving and forethought and enterprise of their forebears, had this money invested, and are drawing a little remuneration from it. I know that the Chancellor would say that the Revenue only presses for payment where the taxpayer can reasonably be expected to pay, but the question is what is reasonable. It is a matter of opinion, and what may appear to the Revenue to be reasonable may appear most unreasonable to those people. I maintain that no company or individual should have to pay any tax on income abroad which they cannot get into this country through no fault of their own.

The fair thing would be to adopt the practice allowed, I believe, during the war. The Chancellor should earmark money in the Argentine, or whatever other country it might be, against such time as those funds are remitted to this country. When they are remitted, by all means let him take an amount of money which will pay the outstanding tax. But to have to pay tax at a rate of exchange far more advantageous than any rate of exchange at which we shall ever be able to get money over, so far as I can see, and out of money which has already paid tax in this country, is a monstrous thing. I hope the Chancellor will consider favourably this new Clause.

Mr. David Renton (Huntingdon)

I must confess to having drafted the exchange control law, back in 1944, of a territory under British control which, so far as I know, is still the law of that territory. I must also confess that when we brought that law into operation, I gave full warning as a lawyer that I did not think the law could be administered effectively. Within a few months it was shown quite clearly that it could not be.

I recollect clearly that there was no provision whatever, although this was a territory under British control—I do not think I ought to mention the name of it, but I am willing to give it to the Chancellor if he wishes—made for dealing with profits accruing within that territory to British subjects who would have to pay tax on them. I mention this just as a personal experience, in order to confirm the statements made by my hon. Friend the Member for Chippenham (Mr. Eccles) about the unsatisfactory state of affairs in other countries.

It appears to me that when a British company in this country is made to pay tax upon profits which are unremittable, it is no better conduct on the part of the Treasury than asking that company to pay a tax on bad debts. It seems to me that in principle it is quite indistinguishable. We know that the Treasury makes allowance in certain cases for bad debts. We know that if the debts turn out to be permanently bad debts, in the case of businesses of professional men, eventually no tax is payable. In common justice, it is just as wrong for the Treasury to try to extract tax on these unremittable profits as it would be for them to extract tax on bad debts.

Mr. W. Fletcher

My conscience is, fortunately, clear of the terrible burden which the hon. Member for Huntingdon (Mr. Renton) must have at present, because I have not been concerned with the drafting of any of these nefarious snares. I support my hon. Friend the Member for Chippenham (Mr. Eccles) wholeheartedly, because I believe that the new pattern of trade and development in an increasing number of territories is that those who are asked to put money into development are more or less warned from the word "go" that for a very long time, owing to the bad financial situation of a great many of these territories, there will be no chance at all of a reasonable remission.

The development has got to be a longterm one. Nearly all these countries are exactly the territories which hon. Gentlemen opposite talk about so glibly and so frequently when they refer to raising the standard of living in the poorer territories. The very fact that they are the poorer territories in many cases enforces on their Governments the need to make exchange control regulations that have exactly the harsh effect which those who have spoken on this new Clause have mentioned. If there really is a desire for this country to play its rôle in the development of the backward areas, then something of the nature mentioned in this Clause must be set in action fairly soon.

I think that my hon. Friend the Member for Chippenham may be a little optimistic in thinking that he is likely to get much help from the Treasury, where they could help. The Chancellor knows perfectly well what happened about the taxe de solidarityéin France, where the legal position was 100 per cent. complicated under the Act but the Treasury never raised a single finger to help, and those concerned had to fight it out not with the consent but almost with the opposition of the Treasury.

It is all the more necessary that we should have a Clause of this sort to assist these companies, established in territories which have already made evil and wicked exchange laws, or made variable rates, which is really a form of Government blackmail. The Government should realise that in the extension of development in which we ought still to be playing a role, something must be done for these companies which, inevitably, when they come to consider this vital work of development must ask, "Shall we do it under this scheme which we know is a good one, but under which for years we will not be allowed to remit; or shall we go to another territory, where perhaps the need is nothing like so great?" The long-term implications of world development under this Clause and under the general policy of the Government should really be taken into consideration by the Chancellor.

Mr. Gaitskell

The subject raised by the hon. Member for Chippenham (Mr. Eccles) in this new Clause was pretty fully discussed last year and, as he reminded the House, as a result of discusions then, a new Clause was inserted into the Finance Bill of last year which I certainly could not describe as a small concession, but which it seems to me made a very material difference to the situation. The concession made then did allow the Inland Revenue, if, in the circumstances, they regarded it as reasonable to do so, to suspend the payment of tax, and therefore, of course, the payment of interest as well, if, owing to the action of the Government of the country concerned, it was impossible to remit the profits.

The hon. Member for Tavistock (Mr. Studholme) referred to the case of a small company with which he was connected, and said that, after writing to me, the Inland Revenue had told him that they would not collect for the moment. I can assure him that that is due to the new Clause which was introduced last year, which gave them power to do this. If I may say so, it was not because of any personal intervention by myself.

Mr. Studholme

If we had to pay the amount of money demanded from us, we should not have had anything left at the bank.

Mr. Gaitskell

That was a very strong case for doing what the Inland Revenue were enabled to do by the new Clause introduced last year.

The proposal in the new Clause goes very much wider than this. I need not repeat the explanation given very clearly by the hon. Member for Chippenham, but the essential point is that it gives the Inland Revenue no option. Automatically, if the remittances are impossible for any reason, then the tax need not be paid.

This is the heart of the matter, and I cannot accede to the proposition which hon. Members opposite have put forward that in all circumstances if it is impossible to remit the money—and we shall have to make the decision whether it is or not—the Inland Revenue should not be paid.

Even in the case of a large company operating no doubt all over the world, and with very large resources, doing extremely well, paying very large dividends to its shareholders, with plenty of money and no difficulty in regard to sterling, nevertheless the Inland Revenue may not collect the tax. That puts the tax collector behind the shareholder, and last of all in the queue. [HON. MEMBERS: "No.") Yes. There is nothing to prevent the company concerned from paying dividends in full, taking into account the profits and ignoring the fact that they are blocked for the moment elsewhere.

What the hon. Member is asking us is that the Inland Revenue may not be paid. in spite of that fact. That is clearly involved in this proposition, and what we say is that the Inland Revenue should have discretion. We recognise that there are cases, such as that which the hon. Member for Tavistock mentioned, in which it is obviously inappropriate that the tax should be collected because the cash in sterling is not available, and that is exactly what happens at the moment, but we do not see why, taking the other extreme, where no hardship is involved and there is no difficulty for the company concerned, the tax should not be taken.

That is the principal point at stake. We think there should be this discretion which was introduced last year, instead of an automatic letting-off of the tax involved. In any case, it is not by any means so simple to be satisfied whether the foreign exchange is or is not available, and whether it is impossible to remit. The hon. Member for Chippenham spoke as if it were a question of all being blocked or none, but he will agree that it is very often the case that a foreign Government allots a particular quota to a particular country, and it is a question whether the company or other claimants get quick enough into the queue to get their share of the quota. I think it would be extremely difficult if a particular company wanted, for one reason or another, to avoid being taxed, to prove that it was because it was late in the queue and could not get its share of the quota, which therefore made it impossible for it to remit.

As for the alternative proposition, it is that the tax should not be collected where the Inland Revenue considered that the exchange rate was unsatisfactory. I really think that that would be very difficult to operate. I should not have thought that it was at all easy for the Inland Revenue to say whether or not it was the right moment to remit. That, surely, should be left to the company.

9.30 p.m.

There are one or two other points which the hon. Member for Chippenham raised to which I should like to refer. He mentioned the difficulty which would arise if the profits were taxed at a particular exchange rate and then could only be remitted later at a much worse rate. Of course, the rate at which the profits are taxed is the same as that at which the profits are estimated in the profit and loss accounts of the company. By and large, of course, the Inland Revenue would simply follow the trading practice. But if that should happen, then, of course, the company has the right to put the loss against the profits of the next year or later years, as the case may be. Therefore, it is not quite the position that the hon. Member seemed to suggest. The Clause also proposes that the repayment of interest should be applied retrospectively. That, of course, is a proposition which I could not accept.

I do not feel that any serious evidence has been put forward this year to show that the system introduced last year is not working pretty reasonably. In those circumstances, I cannot see that we have yet any grounds for believing that a further change in the law is necessary. I would add, however, that this is no doubt one of the subjects which the Royal Commission on Taxation will be looking into. It was referred to briefly in the Tucker Report, but they indicated that the questions raised with them were more proper for the Royal Commission than for themselves to decide.

Mr. Assheton

I think the House listened with great interest to the case made by my hon. Friend the Member for Chippenham (Mr. Eccles). It is not always very easy for those of us not closely concerned with this sort of problem to understand matters of exchange control. They are very confusing even to those who study them, and to those who do not they are almost impossible to understand. But I think it emerged from the speech of my hon. Friend the Member for Chippenham, which was so well supported by the speech of my hon. Friend the Member for Bury and Radcliffe (Mr. W. Fletcher), that there appears to be a clear case of injustice.

What the Revenue are seeking to do is to impose a tax on an income which has not been received. That seems plainly contrary to commonsense. I do not profess to know a great deal about foreign exchange control, but I will, with permission, give an illustration to the House. Supposing one has some rents to collect. When they are collected, one pays tax on them. But if one is unable to collect the rents, then the Revenue remit the tax on the grounds that the income has not been received. They do not say that one has an income from another source, and that therefore one can quite well pay the tax on the rents not received. It seems to me that the case made from this side is quite clear, and if my hon. Friend seeks to divide the House on this Clause, I shall be happy to go into the Lobby with him.

Mr. Pitman

I think there is one point on which the Chancellor has either been misled by his Department or on which he is unwittingly misleading the House, and that is on the question of book-keeping. As I understood him—and I listened carefully to his speech—one of his chief reasons for rejecting this Clause is that he says it would be possible for a company to distribute a full dividend although it was, in point of fact, making much of its profits overseas, on which it would not be paying tax.

Mr. Gaitskell

I did not say "much of its profits." I said it would be possible for the company to distribute a full dividend, taking into account the profits earned overseas, because it has plenty of cash.

Mr. Pitman

That was the point I had in mind, because in that particular case the directors would be culpable if they did not set aside a provision in the accounts for the contingent of tax. Any auditor would definitely insist that such a provision should be made. So if that really is the substance of the Chancellor's objection, I hope he will consider it and see that the Treasury consider it.

Mr. F. Harris

I listened very carefully to the Chancellor and I wish that the Chancellor, the Financial Secretary and the Treasury could address their arguments with more firmness to the points raised. It seems to me blatantly unfair for the Government to take the line that when money is not able to be transferred they can nevertheless take taxation as they so desire, merely because a company has additional profits from which the Treasury may draw additional taxation.

If one follows that argument through, a company which in the past may have transferred its profits fairly regularly into this country and is therefore well placed as far as funds are concerned, is liable to pay tax on profits that cannot be transferred at present and it has that liability merely because it has the money; whereas a company which is not in a position to pay the tax and which the tax might break if it had to pay it, is in a different position. It seems to me a case of one law for the rich and one for the poor, and it seems an extraordinary argument to pursue.

My hon. Friend the Member for Bath (Mr. Pitman) has brought forward the obvious fact of bookkeeping as far as profits are concerned. It must have seemed strange to anybody who listened to the Chancellor and his arguments that he should put forward the suggestion that a company may go on paying dividends based on profits that are not transferred. That seems an extraordinary action for any company director to take, and I do not think that when he put it to the House the Chancellor himself believed in that suggestion for one moment.

I suggest, therefore, that it is a great pity that the Chancellor and the Treasury cannot address their arguments more seriously to the facts put forward. Anybody who heard one of my hon. Friends who produced his own individual case must have been impressed by the seriousness of the position which arises in other countries relative to our own.

Lieut.-Commander Braithwaite

I thought that the Chancellor's reply was somewhat parochial or insular because, after all, this problem arose out of what is surely a typical post-war development all over the world. These exchange restrictions are an irritating form of economic nationalism of which this country itself has not been guiltless. I should like to hear the right hon. Gentleman say that, although he has expressed the view that this year he is not prepared to alter the internal machinery for the collection of this taxation, he proposes at high governmental level to conduct negotiations with countries where these balances are locked.

I think it was my hon. Friend the Member for Chippenham (Mr. Eccles), who made the point, when moving the Clause, that a private company is in a much more difficult position in obtaining its money than would be His Majesty's Government. When we have representatives in the Argentine, for instance—where the Economic Secretary to the Treasury was the other day—one would think that

would be a particularly good opportunity to discuss this sort of difficulty. After all, it is an international difficulty and if these balances could be transferred, knowing that on arrival in this country they would be available for taxation it seems to me that, while not everyone would be happy —because that is never the case where taxation is concerned—one of the chief difficulties of this problem would have been solved.

May I say, in conclusion, what a great delight it was to us on this side of the House to hear a speech from my hon. Friend the Member for Tavistock (Mr. Studholme), who is usually associated with other and disciplinary activities?

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

The House divided: Ayes, 263; Noes, 290.

Division No 155.] Ayes [9.40 p.m
Aitken, W. T. Crosthwaite-Eyre, Col. O. E. Hill, Dr. Charles (Luton)
Alport, C. J. M. Crouch, R. F. Hill, Mrs. E. (Wythenshawe)
Amery, Julian (Preston, N.) Crowder, Capt. John (Finchley) Hinchingbrooke, Viscount
Amory, Heathcoat (Tiverton) Crowder Petre (Ruislip—Northwoood) Hirst, Geoffrey
Arbuthnot, John Cundiff, F. W. Hollis, M. C.
Ashton, H. (Chelmsford) Darling, Sir William (Edinburgh, S) Holmes, Sir Stanley (Harwich)
Assheton, Rt. Hon. R. (Blackburn, W) Davies, Nigel (Epping) Hope, Lord John
Astor, Hon. M. L. de Chair, Somerset Hopkinson, Henry
Baldock, Lt.-Cmdr J M De la Bére, R. Hornsby-Smith, Miss P
Baldwin, A. E. Deedes, W. F. Horsbrugh, Rt. Hon. Florence
Banks, Col. C Digby, S. Wingfield Howard, Gerald (Cambridgeshire)
Baxter. A B Dodds-Parker, A. D Howard, Greville (St. Ives)
Beamish, Maj. Tufton Donner, P. W. Hudson, Sir Austin (Lewisham, N.)
Bell, R. M. Douglas-Hamilton Lord Malcolm Hudson, Rt. Hon. Robert (Southport)
Bennett, Sir Peter (Edgbaston) Drayson, G. B. Hudson, W. R. A. (Hull, N.)
Bennett, Dr. Reginald (Gosport) Drewe, C. Hulbert, Wing Cmdr. N. J.
Bennett, William (Woodside) Dugdale Maj. Sir Thomas (Richmond) Hurd, A. R.
Bevins, J. R. (Liverpool, Toxteth) Duncan, Capt J. A. L. Hutchinson, Geoffrey (llford, N.)
Birch, Nigel Dunglass, Lord Hutchison, Lt.'Com. Clark (E'b'rgh W)
Bishop. F. P. Duthie, W. S. Hutchison, Col. James (Glasgow)
Black, C. W. Eccles, D. M. Hylton-Foster, H. B.
Boles, Lt.-Col. D. C (Wells) Errol. F. J. Jeffreys, General Sir George
Bossom.A. C. Fisher, Nigel Jennings, R.
Boyd-Carpenter, J. A Fletcher, Walter (Bury) Johnson, Howard (Kemptown)
Boyle, Sir Edward Fort, R. Jones, A. (Hall Green)
Bracken, Rt. Hon B Foster, John Joynson-Hicks, Hon. L. W.
Braine, B. R. Fraser, Hon. Hugh (Stone) Kaberry, D.
Braithwaite, Sir Albert (Harrow, W) Fyfe, Rt. Hon. Sir David Maxwell Kerr, H. W. (Cambridge)
Braithwaite, Lt.-Cdr. G. (Bristol, N.W) Gage, C. H. Kingsmill, Lt.-Col. W. H
Bromley-Davenport, Lt.-Col. W Galbraith, Cmdr. T. D. (Pollok) Lambert, Hon G
Brooke, Henry (Hampstead) Galbraith, T. G. D. (Hillhead) Lancaster, Col. C. G
Browne, Jack (Govan) Gammam, L. D. Langford-Holt, J.
Buchan-Hepburn, P. G. T Garner-Evans, E. H. (Denbigh) Law, Rt. Hon. R. K.
Bullus, Wing Commander E E Gates, Maj. E. E. Leather, E. H. C.
Burden, F. A. Glyn, Sir Ralph Legge-Bourke, Maj. E. A. H
Butcher, H. W. Gridley, Sir Arncld Lennox-Boyd, A. T.
Butler, Rt. Hn. R. A. (Saffron Walden) Grimston, Hon. John (St. Albans) Lindsay, Martin
Carr, Robert (Mitcham) Grimston, Robert (Westbury) Linstead, H N.
Carson, Hon. E. Hare, Hon. J. H. (Woodbridge) Lloyd, Rt. Hn. G. (King's Norton)
Channon, H. Harris, Frederic (Croydon, N.) Lloyd, Maj. Guy (Renfrew, E.)
Clarke, Col. Ralph (East Grinstead) Harris, Reader (Heston) Lloyd, Selwyn (Wirral)
Clarke, Brig. Terence (Portsmouth, W.) Harvey, Air Codre. A. V. (Macclesfield) Lockwood. Lt.-Col. J. C.
Clyde, J. L. Harvey, Ian (Harrow, E.) Longden, Gilbert (Herts, S.W.)
Conant, Maj. R. J. E. Harvie-Watt, Sir George Low, A. R. W.
Cooper, Sqn. Ldr. Albert (llford, S) Hay, John Lucas, Sir Jocelyn (Portsmouth. S.)
Cooper-Key, E. M. Head, Brig. A. H. Lucas, P. B. (Brentford)
Corbett, Lt.-Col. Uvedale (Ludlow) Headlam, Lt.-Col. Rt. Hn. Sir Cuthbert Lucas-Tooth, Sir Hugh
Craddock, Beresford (Spelthorne) Heald, Lionel McAdden, S. J.
Cranborne, Viscount Hicks-Beach, Maj. W W McCorquodale, Rt. Hon. M. S.
Crookshank, Capt. Rt. Hon. H. F. C. Higgs, J M C Macdonald, Sir Peter (I. of Wight)
Mackeson, Brig. H. R. Peto, Brig C. H M Stuart, Rt. Hon. James (Meray)
McKibbin, A. Pickthorn, K. Summers, G. S
McKie, J. H. (Galloway) Pitman, I. J. Sutcliffe, H.
Maclay, Hon. John Powell, J. Enoch Taylor, Charles (Eastbourne)
Maclean, Fitzroy Price, Henry (Lewisham, W) Taylor, William (Bradford, N.)
MacLeod, Iain (Enfield, W.) Prior-Palmer, Brig, O. Teevan, T. L.
MacLeod, John (Ross and Cromarty) Profumo, J. D. Thomas, J. P. L. (Hereford)
Maitland, Cmdr. J. W. Raikes, H. V. Thompson, Kenneth Pugh (Walton)
Manningham-Buller, R. E Rayner, Brig. R. Thompson, Lt.-Cmdr. Ft. (Croydon, W.)
Marlowe, A. A. H Redmayne, M. Thorneycroft, Peter (Monmouth)
Marples, A. E. Remnant, Hon. P. Thornton-Kemsley, Col. C. N.
Marshall, Douglas (Bodmin) Renton, D. L. M. Thorp, Brig. R. A. F.
Marshall, Sidney (Sutton) Roberts, Maj. Peter (Heeley) Tilney, John
Maude, Angus (Ealing, S.) Robertson, Sir David (Caithness) Touche, G. C.
Maude, John (Exeter) Robinson, Roland (Blackpool, S) Turner, H. F. L
Maudling, R. Robson-Brown, W. Turton, R. H.
Mellor, Sir John Rodgers, John (Sevenoaks) Tweedsmuir, Lady
Molson, A H. E Roper, Sir Harold Vane, W. M. F.
Monckton, Sir Walter Russell, R. S. Vaughan-Morgan. J. K.
Meore, Lt -Col. Sir Thomas Ryder, Capt. R. E. D. Wakefield, Edward (Derbyshire, W)
Morrison, John (Salisbury) Salter, Rt. Hon. Sir Arthur Walker-Smith, D. C.
Morrison, Rt. Hon. W. S (Cirencester) Sandys, Rt. Hon. D. Ward, Hon. George (Worcester)
Mott-Radclyffe, C. E Savory, Prof. D. L. Ward, Miss I. (Tynemouth)
Nabarro, G Scott, Donald Waterhouse, Capt. Rt Hon C
Nicholls, Harmar Shepherd, William Watkinson, H.
Nicholson, G. Smiles, U.-Col. Sir Walter Webbe, Sir H. (London)
Noble, Cmdr. A. H. P. Smithers, Peter (Winchester) Wheatley, Maj. M. J. (Poole)
Nugent. G. R. H. Smyth, Brig. J. G (Norwood) White, Baker (Canterbury)
Nutting, Anthony Snadden, W. McN. Williams, Charles (Torquay)
Oakshott, H. D. Soames, Capt. C. Williams, Gerald (Tonbridge)
Odey, G. W. Spearman, A. C. M. Williams, Sir Herbert (Croydon, E)
O'Neill, Rt. Hon. Sir Hugh Spence, H. R. (Aberdeenshire, W) Wills, G.
Ormsby-Gore. Hon. W. D Spens, Sir Patrick (Kensington, S.) Wilson, Geoffrey (Truro)
Orr, Capt. L. P. S. Stanley, Capt. Hon. Richard (N. Fylde) Wood, Hon R
Orr-Ewing, Charles Ian (Hendon, N,) Stevens, G. P. York, C
Orr-Ewimg, Ian L. (Weston-super-Mare) Steward, W. A. (Woolwich. W)
Osborne, C. Stoddart-Scott, Col. M. TELLERS FOR THE AYES:
Peake, Rt. Hon O Storey, S. Mr. Studholme and Mr. Vosper.
Perkins, W. R. D. Strauss, Henry (Norwich, S)
NOES
Acland, Sir Richard Cocks, F. S. Foot, M. M.
Adams, Richard Coldrick, W. Fraser, Thomas (Hamilton)
Albu, A. H Collick, P. Freeman, John (Watford)
Allen, Arthur (Bosworth) Collindridge, F. Freeman, Peter (Newport)
Allen, Scholefield (Crewe) Cook, T. F. Gaitskell, Rt. Hon. H. T. N.
Anderson, Alexander (Motherwell) Cooper, Geoffrey (Middlesbrough, W.) Ganley, Mrs. C. S.
Anderson, Frank (Whitehaven) Cooper, John (Deptford) George, Lady Megan Lloyd
Attlee, Rt. Hon. C R Cove, W. G. Gibson, C. W.
Awbery, S. S. Craddock, George (Bradford, S) Gilzean, A.
Ayles, W. H. Crawley, A. Glanville, James (Consett)
Baird, J. Crosland, C. A. R. Gordon-Walker, Rt. Hon. P C.
Balfour, A. Crossman, R. H. S Granville, Edgar (Eye)
Barnes, Rt. Hon A. J Cullen, Mrs. A. Greenwood, Anthony (Rossendale)
Bartley, P. Daines, P. Greenwood, Rt. Hon. Arthur (Wakefield)
Bellenger, Rt. Hon. F. J. Dalton, Rt. Hon. H. Grenfell, Rt. Hon. D. R.
Bonn, Wedgwood Darling, George (Willsborough) Grey, C. F.
Benson, G. Davies, A. Edward (Stoke, N.) Griffiths, David (Rother Valley)
Beswick, F. Davies, Ernest (Enfield, E.) Griffiths, Rt. Hon. James (Llanelly)
Bevan, Rt. Hon. A. (Ebbw Vale) Davies, Harold (Leek) Griffiths, W. (Manchester Exchange)
Bing, G. H. C Davies, Stephen (Merthyr) Gunter, R. J.
Blenkinsop, A. de Freitas, Geoffrey Haire, John E. (Wycombe)
Blyton, W. R. Deer, G. Hale, Joseph (Rochdale)
Boardman, H Delargy, H. J. Hale, Leslie (Oldham, W.)
Booth, A. Diamond, J. Hall, Rt. Hon. Glenvil (Colne Valley)
Bottomley, A. G. Dodds, N. N. Hall, John (Gateshead, W.)
Bowden, H. W. Donnelly, D. Hamilton, W. W.
Bowles, F. G. (Nuneaton) Driberg, T. E. N. Hannan, W.
Braddock, Mrs. Elizabeth Dugdale, Rt. Hon. John (W. Bromwich) Hardy, E. A.
Brock, Dryden (Halifax) Ede, Rt. Hon. J. C. Hargreaves, A.
Brocks, T. J. (Normanton) Edelman, M. Hastings, S.
Broughton, Dr. A. D. D Edwards, John (Brighouse) Hayman, F. H.
Brown, Rt. Hon. George (Belper) Edwards, Rt. Hon. Ness (Caerphilly) Henderson, Rt. Hon. A. (Rowley Regis)
Brown, Thomas (lnce) Edwards, W J. (Stepney) Hobson, C. R
Burke, W. A. Evans, Albert (Islington, S.W) Holman, P.
Burton, Miss E. Evans, Edward (Lowestoft) Holmes, Horace (Hemsworth)
Butler, Herbert (Hackney, S.) Evans, Stanley (Wednesbury) Houghton, D.
Callaghan, L. J. Ewart, R. Hoy, J.
Carmichael, J. Fernyhough, E. Hubbard, T.
Castle, Mrs. B. A Field, Capt. W J Hudson, James (Ealing, N.)
Champion, A. J Finch, H. J. Hughes, Emrys (S. Ayrshire)
Chetwynd, G R Fletcher. Eric (Islington, E) Hughes, Hector (Aberdeen, N.)
Clunie, J. Follick, M. Hughes, Mcelwyn (Islington, N.)
Hynd, H. (Accrington) Moeran, E. W. Snow, J. W.
Hynd, J. B. (Attercliffe) Monslow, W. Sorensen, R. W.
Irvine, A. J. (Edge Hill) Moody, A. S. Soskice, Rt. Hon. Sir Frame
Irving, W. J. (Wood Green) Morgan, Dr. H. B Steele, T.
Isaacs, Rt. Hon. G. A. Morley, R. Strauss, Rt. Hon. George (Vauxhall)
Janner, B. Morris, Percy (Swansea, W.) Stross, Dr. Barnett
Jay, D. P. T. Mort, D. L. Summerskill, Rt. Hon. Edith
Jeger, George (Goole) Moyle, A. Sylvester. G. O
Jeger, Dr. Santo (St. Pancras. S.) Mulley, F. W. Taylor, Bernard (Mansfield)
Jenkins, R. H. Murray, J. D. Taylor, Robert (Morpeth)
Johnson, Jamas (Rugby) Nally, W. Thomas, David (Aberdare)
Johnston, Douglas (Paisley) Neal, Harold (Bolsover) Thomas, George (Cardiff)
Jones, David (Hartlepool) Noel-Baker, Rt. Hon. P. J. Thomas, Iorwerth (Rhondda, W.)
Jones, Frederick Elwyn (West Ham, S.) O'Brien, T. Thomas, Ivor Owen (Wrekin)
Jones, Jack (Rotherham) Oldfteld, W. H. Thorneyeroft, Harry (Clayton)
Jones, William Elwyn (Conway) Oliver, G. H. Thurtle, Ernest
Keenan, W Orbach, M. Timmons, J.
Kenyon, C. Padley, W. E Tomney, F.
Key, Rt. Hon. C. W Paget, R. T. Turner-Samuels, M.
King, Dr. H. M. Paling, Rt. Hon. W. (Dearne Valley) Ungoed-Thomas, Sir Lynn
Kinghorn, Sqn Ldr E Paling, Will T. (Dewsbury) Usborne, H.
Kinley, J. Pannell, T. C. Vernon, W. F.
Kirkwood, Rt. Hon. D Pargiter, G. A Viant, S. P.
Lang, Gordon Parker, J. Wallace, H. W
Lee, Miss Jennie (Cannock) Paton, J. Watkins, T. E.
Lever, Harold (Cheetham) Peart, T. F Webb, Rt. Hon. M. (Bradford, C)
Lever, Leslie (Ardwick) Popplewell, E Weitzman, D.
Lewis, Arthur (West Ham, N) Porter, G. Wells, Percy (Faversham)
Lewis, John (Bolton, W.) Price, Joseph T. (Westhoughton) Wells, William (Walsall)
Lindgren, G. S. Price, Philips (Gloucestershire. W.) West, D. G.
Lipton, Lt.-Col. M Proctor, W. T White, Mrs. Eirene (E. Flint)
Logan, D. G. Pryde, D. J. White, Henry (Derbyshire, N E)
Longden, Fred (Small Heath) Pursey, Cmdr. H Whiteley, Rt. Hon. W.
McAllister, G. Rankin, J. Wigg, G.
MacColl, J. E. Rees, Mrs. D. Wilcock, Group Capt. C. A. B
McGhee, H. G. Reeves, J. Wilkes, t.
McGovern, J. Reid, Thomas (Swindon) Wilkins, W. A.
Mclnnes J Reid, William (Camlachie) Willey, Frederick (Sunderland)
Mack, J. D. Rhodes, H. Willey, Octavius (Cleveland)
McKay, John (Wallsend) Richards, R. Williams, David (Neath)
Mackay, R. W. G. (Reading, N.) Robens, Rt. Hon. A Williams, Rev. Llywelyn (Abertillery)
McLeavy, F. Roberts, Emrys (Merioneth) Williams, Ronald (Wigan)
MacMillan, Malcolm (Western Isles) Roberts, Goronwy (Caernarvonshire) Williams, Rt. Hon. Thomas (Don V'lly
McNeil, Rt. Hon. H. Robertson, J. J. (Berwick) Williams, W. T. (Hammersmith, S.)
MacPherson, Malcolm (Stirling) Robinson, Kenneth (St. Pancras, N) Wilson, Rt. Hon. Harold (Huyton)
Mainwaring, W. H. Rogers, George (Kensington, N.) Winterbottom, Ian (Nottingham, C.)
Mallalieu, J. P. W (Huddersfield E) Ross, William Winterbottom, Richard (Brightside)
Mann, Mrs. Jean Royle, C. Wise, F. J.
Manuel, A. C. Shackleton, E. A. A. Woodburn, Rt. Hon A
Mathers, Rt. Hon G Shinwell, Rt. Hon. E. Woods, Rev. G S
Mayhew, C. P Silverman, Julius (Erdington) Yates, V. F.
Mellish, R. J. Silverman, Sydney (Nelson) Younger, Rt. Hon K
Messer, F. Simmons, C. J.
Middleton, Mrs. L Slater, J. TELLERS FOR THE NOES:
Mikardo, Ian. Smith, Ellis (Stoke, S.) Mr. Pearson and Mr. Sparks.
Mitchison, G. R Smith, Norman (Nottingham. S.)