HC Deb 05 July 1960 vol 626 cc321-36
The Financial Secretary to the Treasury (Sir Edward Boyle)

I beg to move, in page 23, line 24, at the beginning to insert "subsections (2) and (3) of".

The Temporary Chairman (Mr. F. Blackburn)

I understand that this Amendment goes with the following one, in page 23, line 25, at end insert "after due deduction of tax".

Sir E. Boyle

Yes, Mr. Blackburn.

Soldiering on, as the hon. Member for Sowerby (Mr. Houghton) would say, we now come to the Amendments to Clause 26. The two substantive Government Amendments to the Clause are both in the direction of tightening up the Clause. If I interpreted correctly the feelings of hon. Members in Committee, that will not be unwelcome.

The second of the two Amendments arises in this way and I take the second one first because this should make my exposition clearer. As the Committee is aware, the Clause is devised to make the seller of what might be called a manufactured dividend liable to the Revenue for tax on that dividend. As originally drafted, the Clause would only charge tax on the net payment for which the seller was required to pay under his contract, not on the gross payment, the tax on which, as the Clause was originally drafted, the Inland Revenue was at risk of having to repay.

The defect arises in this way. The Clause as it now is works by making the seller of the manufactured dividend liable to tax as if he had made an actual payment falling within Section 170 of the 1952 Act. The defect arose on the original drafting of the Clause, because it said that Section 170 was to apply as if the payment by the seller fell within that Section. We have completely remedied that defect by saying that Section 170 shall apply as if the payment were an annual payment made after due deduction of tax. Thus the Amendment will require the seller to account for tax on the gross amount of the payment—that is to say, the tax which he pretends he has borne.

The first of the two Amendments is a drafting and paving Amendment for the second one, which I have just described. Subsections (2) and (3) of Section 170 impose the charge in respect of payments to which that Section applies. It is only necessary, therefore, to apply those two subsections to payments falling under the Clause. Subsection (1) of Section 170, which describes the payments within the Section, cannot be applied to the Clause now that it specifies that the manufactured dividend is to be treated as an annual payment within the charge imposed by Section 170 made after due deduction of tax.

It is our belief that we have now dealt with the point. There is no danger now that tax will be charged only on the net payment and not on the gross payment. I hope that with this explanation, the Committee may agree to the two Amendments.

Mr. Diamond

If it is not the intention of any other hon. Member to address the Committee, I would seek leave, Mr. Blackburn, at this moment to move the Amendment in the name of my hon. Friend the Member for Glasgow, Craig-ton (Mr. Millan) and myself.

The Temporary Chairman

I call the hon. Member for Gloucester (Mr. Diamond).

Mr. Diamond

I beg to move, as an Amendment to the proposed Amendment, to leave out "and (3)" and insert "(3) and (4)".

This is a simple Amendment. Looking at Section 170 I can quite see the reasons for making reference to parts of that Section instead of the whole of it inasmuch as subsection (1) of that Section is no longer needed. What I am unable to see is why it would not be an advantage to retain subsection (4).

The effect of my Amendment would be that the Chancellor's Amendment would read "at the beginning, insert subsections (2), (3) and (4)." We are really only dealing with the addition of subsection (4) which seems to give advantages to the Revenue in enabling it to deal with any assessment which arises in this way. I have no doubt that there is an explanation for it, and that the Government would not have overlooked such a simple matter as the last subsection of a Section and I am sure that they will give a very adequate answer.

Sir E. Boyle

I will give as simple an explanation as I can. The point is that subsections (2) and (3) of Section 170 of the 1952 Act contain the charging provisions and subsection (4) is simply the machinery provision which relates to appeals against assessment in connection with tax and so on.

I have taken the best advice that I can on this and I am assured that the application of subsections (2) and (3) automatically brings in the machinery provisions of subsection (4). Therefore the specific application of and reference to subsection (4) in this Clause is unnecessary. I have taken the best advice I can. There is no difference between us as to the aim that we wish to achieve and I hope that with that explanation the hon. Gentleman may feel able to withdraw his Amendment.

Mr. Mitchison

As a matter of fact, subsection (3) is really a machinery subsection, too, and I cannot quite see why the Government should not put in a specific reference to subsection (4). I do not want to argue the point, but if we put in two subsections and pointedly, as it were, omit the other, there may be some doubt in the matter. But, again, as the Scotsman said about the holy water, if I am not being irreverent "It can do no harm and it may do some good". I hope that the Government will accept the Amendment if only as a small tribute to the excellent work that my two hon. Friends the Member for Gloucester (Mr. Diamond) and the Member for Glasgow, Craigton (Mr. Millan), who like to be mentioned together, have done throughout the proceedings on this Bill.

Sir E. Boyle

On the last point of the hon. and learned Member for Kettering (Mr. Mitchison), may I say that I have heard tributes in the last half hour to the two hon. Members to whom he referred. I gladly join in those tributes, and I hope that at a later stage of the Bill I shall have the chance of distributing one or two prizes.

On the specific point under discussion I am assured that it is unnecessary to mention subsection (4) here and I must on that point stand on the advice that I have given to the Committee.

Mr. Diamond

I am invited to withdraw the Amendment on being satisfied that it is not necessary. I wish that I could say that I was satisfied. I heard what the Financial Secretary has said but I am certainly not satisfied. I admit that I know nothing about drafting and I am not a lawyer, but I am told that the reason we do not include subsection (4) is that we want that subsection in the Clause. This does not seem to me the most powerful reason that the Financial Secretary could have adduced. In view, however, of the responsibility that he takes in making the statements, and the advice that he has in making them, I would not dream of inviting any hon. Friend of mine to press the matter to a Division, but I cannot withdraw the Amendment.

The Temporary Chairman (Mr. Blackburn)

The Question is—

Mr. Mitchison

May I point out, Mr. Blackburn, that my hon. Friend the Member for Gloucester (Mr. Diamond) did not withdraw his Amendment or ask leave to do so?

The Temporary Chairman

I am sorry. I misunderstood the hon. Member for Gloucester.

5 (4) Where the seller is resident in the United Kingdom and purchased the securities (otherwise than through a broker) from a person not so resident, then except where the contract for that purchase was made before the seventh day of July, nineteen hundred and sixty, paragraph (b) of subsection (1) of this section shall have effect as if after the word "say" there were inserted the word "either" and as if for the words from "either as" to the end of the paragraph there were inserted the words "as the registered holder of the securities or that he shows to the satisfaction of the Special Commissioners that he acquired the securities, directly or indirectly, from a person who was so entitled to the payment".
10 (5) Where the seller under such a contract as is mentioned in paragraph (a) of subsection (1) of this section is not resident in the United Kingdom, and the sale is effected through a broker, that subsection shall not apply but, except where the contract was made before the seventh day of July, nineteen hundred and sixty, unless the broker shows to the satisfaction of the Special Commissioners either that the seller was entitled to the payment of interest as the registered holder of the securities or that the seller acquired the securities, directly or indirectly, from a person who was so entitled to the payment, subsections (2) and (3) of section one hundred and seventy of the Act of 1952 shall apply as if the payment through the broker of the amount of the payment of interest were an annual payment by the broker made, after due deduction of tax, wholly out of such a source as is mentioned in the said subsection (1).
15
20

This is quite an important Amendment, although I do not think that I need spend very long in explaining it. It introduces two new subsections which are to deal with the possibility that dividends may be manufactured by persons resident abroad who sell the securities in question either directly or indirectly through the Stock Exchange at this end.

As it stands, the Clause imposes a theoretical charge on a non-resident who sells what has been termed for the purpose of the Clause a manufactured dividend, but the liability would, in practice, be unenforceable as the Clause stands because the Revenue would probably be unable to track down the seller or collect the tax from him if it did. Inquiries have been received about the position under the Clause where non-residents sell cum-dividend. If the weaknesses of the Revenue's position became known without any further subsection being added there is a real danger of the purpose of the Clause being greatly jeopardised.

Let me explain briefly to the Committee the two new subsections (4) and (5) which I am now proposing. The new subsection (4) endeavours to guard against the possibility that a resident in

Amendment to the proposed Amendment negatived.

Proposed words there inserted.

Amendment made: In page 23, line 25, at end insert "after due deduction of tax".—[Sir E. Boyle.]

Sir E. Boyle

I beg to move, in page 23, line 42, at the end to insert:

the United Kingdom may buy from a foreign seller securities with a manufactured dividend and in turn sell these securities under a contract whereby he has to account for the dividend to the final purchaser. Subsection (4) plants a liability to account to the Revenue for tax in respect of any dividend on securities sold, in circumstances falling within subsection (1, a) of the Clause, by a resident who had purchased the securities from a non-resident, unless the resident was directly entitled to the interest as the registered holder of the securities or shows to the satisfaction of the Special Commissioners that he acquired the securities, directly or indirectly, from a person who was so entitled to the payment. That means that if a seller abroad manufactured the dividend, and a United Kingdom purchaser from him sold cum-dividend, the person in the United Kingdom would have to find the tax on the dividend. If the non-resident was himself the registered holder of the securities or had bought them from another person who was so registered then it would be up to the United Kingdom resident, either by producing the dividend voucher or otherwise, to show that he was outside the scope of the subsection. This means that a United Kingdom purchaser direct from a foreign seller will have to make sure that he is buying a genuine dividend from the person overseas, and if not he himself would be in a very disadvantageous position with the Revenue.

8.0 p.m.

Subsection (5) deals with a case where a non-resident sells securities cum dividend on the United Kingdom Stock Exchange through a broker in circumstances that fall within subsection (1, a) of the Clause. In that case the broker is made liable to account for tax on the dividend to the Revenue unless he can show that the non-resident seller was entitled to payment of dividend as a registered holder, or acquired the securities directly or indirectly from a person so entitled.

As far as I can see, these two subsections are watertight. They will guard against the danger we obviously have to consider very carefully that dividends may be manufactured by persons resident abroad selling securities through the Stock Exchange. This is an important Amendment for the purpose of ensuring that the Clause does its job.

Mr. Diamond

Before moving to the Amendment to the proposed Amendment in my name and in that of my hon. Friend the Member for Glasgow, Craigton (Mr. Millan), I accept entirely—

The Temporary Chairman (Mr. F. Blackburn)

I take it that the hon. Member knows that only the second and third of his Amendments put down to the proposed Amendment, those in lines 8 and 16, are selected.

Mr. Diamond

I am grateful to you, Mr. Blackburn. I was not aware whether the fourth Amendment, in line 17, was originally selected but it seems now that there would be no longer any point in moving it.

The Temporary Chairman

It deals with a matter we have already disposed of and therefore falls.

Mr. Diamond

Perhaps it will be simpler if I move the first of my two selected Amendments to the proposed Amendment and also speak to the second which would insert "cum dividend" in line 16.

I beg to move, as an Amendment to the proposed Amendment, in line 8, after "securities" to insert "cum-dividend".

I am pleased but a little bemused at the Financial Secretary's world of fantasy where there is apparently this method of creating counterfeit money, that is, a tax deduction voucher not based on reality but which is a completely fraudulent document. There is this oppportunity of creating counterfeit money in such a way as is not illegal and which can be done, not, as we thought, merely by operations on the Stock Exchange here between residents, but also by non-residents. One talks of this matter with some diffidence because it is a new realm of avoidance about which one knew nothing, and it comes to light only as the Government give examples of it.

I entirely accept that the proposed provisions are valuable, but if there is value in third or fourth thoughts one wonders what the fifth or sixth thoughts will be and what further thoughts it will be necessary to put into legislation next year notwithstanding the Financial Secretary's brave words—and no one hopes more than I do that he will not have to swallow them—that this is a watertight Government Amendment. This is a shocking state of affairs. As the Attorney-General said on Second Reading, it is not a question of tax avoidance only. It goes far beyond that.

My Amendments to the proposed Amendment are intended merely to make clear that the acquisition of securities is intended to mean the acquisition of securities cum-dividend and it is, therefore, surely more explicit if the words "cum-dividend" are inserted. The Amendment to the Amendment makes clear that the buyer who acquires securities and subsequently sells them and creates dividends in this way is a buyer who has bought cum-dividend.

Mr. Glenvil Hall

I wonder whether the Financial Secretary will give us some idea of the extent of this practice to which the Amendment was directed. I am filled with gloom and despondency by the fact that here, on Recommittal, weeks and weeks after the Finance Bill has been printed, circulated and discussed and when, as far as we knew, the Government had put in provisions to deal with this kind of thing. this now comes to light and has to be dealt with at this late hour. Could the Financial Secretary give us some idea how long this kind of thing has been going on? I take it that it is not too widespread, but apparently it has been going on for some time. Can he tell us how far it has gone?

Mr. Mitchison

On a point of order. I wanted to make a few observations relevant to the main Amendment. I understand that we are now discussing simply the question whether "cum-dividend should be inserted after the word "securities".

The Temporary Chairman

Only the hon. Member for Gloucester (Mr. Diamond) rose to his feet when I put the Question, and therefore I called him, taking it that no other hon. Member wished to speak.

Mr. Mitchison

I am not in any way dissenting from that. I am inquiring whether I should say now what I have to say or after we have dealt with the Amendment to the Amendment.

The Temporary Chairman

I think that it would be better if we got rid of the Amendment to the Amendment first of all.

Sir E. Boyle

I propose to reply to the Amendment to the Amendment and on the main Amendment I might reply to the right hon. Member for Colne Valley (Mr. Glenvil Hall). I think that I can put the fears of the hon. Member for Gloucester (Mr. Diamond) at rest. He has a perfectly reasonable point. The position under the new subsection (4) is that if a United Kingdom resident buys securities ex-dividend from a nonresident registered holder and sells them cum a manufactured dividend, the payment of interest—the amount of which he has to pay to the purchaser under his contract for sale—will not be the payment of interest to which the registered holder was entitled. Therefore the seller will not be able to satisfy conditions for exemption from the Clause.

The key words I commend to the hon. Member for Gloucester are the words "the payment". That means the payment of interest, in the closing words of subsection (1, b), because these words, as applied to subsection (4), must be taken as meaning the payment of interest which the seller has to hand on under his contract for sale.

As for subsection (5), dealing with sales by a non-resident through a broker, the Clause will apply in practice in the following way. A non-resident seller of securities cum dividend has made a contract under which he has to pay to the purchaser the amount of a periodical payment of interest so as to bring subsection (5) into operation. Here again there would be no exemption for the case where the seller acquired the shares ex-dividend from the registered holder, because the payment to which the registered holder is entitled is not then the payment of interest—the amount of which the seller has to pay to the purchaser. This means that the hon. Member's Amendments to the Amendment are not really necessary.

On the other hand, I agree in principle that the Amendments to the Amendment are perfectly reasonable and I would advise the Committee to accept them but for one thing. This is that they would not do in the form in which they are drafted, because I am advised that no meaning could be attached legally to the phrase "cum dividend" without definition. The Clause refers to a contract … under which the seller is required to pay to the purchaser the amount of a periodical payment of interest … and the words "cum dividend" are what a non-laywer would call a useful shorthand reference to such a contract, but they would not do in the Clause on their own. I am quite certain that the Amendments to the Amendment are not necessary. In principle there is no harm in them, but I hope that with this explanation the hon. Member will be ready to withdraw the Amendment to the Amendment.

Mr. Diamond

I am grateful to the Financial Secretary for his very lucid reply on a difficult and abstruse subject. I anticipated that there would be a difficulty. The reason why I had the temerity to table my Amendments is that the rubric to the Clause says: Sale of securities cum-dividend. In my simplicity. I assumed that if the rubric referred to sales cum-dividend the Government knew what they were talking about and that there was some meaning to be attached to the words.

In view of the assurance that the Government do not know what they are talking about and that no meaning attaches to the term "cum-dividend", and if the hon. Gentleman says that for the purpose of the Statute there is no close definition of "cum-dividend", as I imagine he may, and also having regard to the very full reply which the Financial Secretary has made and the consideration which he has given to the point, for which I am grateful, I beg to ask leave to withdraw the Amendment to the proposed Amendment.

Amendment to the proposed Amendment, by leave, withdrawn.

Mr. Mitchison

I support the request made by my right hon. Friend the Member for Colne Valley (Mr. Glenvil Hall) for a little more information about what has been happening in this connection.

I am afraid that the Financial Secretary will never qualify for membership of the I.T.D.A.—The International Tax Dodgers' Association. I did not know that it existed, but it rather looks as if it does. We should all like to know what has provoked this Clause, how serious the provocation has been and how long it has been going on—if, indeed, it has been going on.

Mr. Diamond

My hon. and learned Friend is jocularly referring to a most serious matter. He is talking about the International Tax Dodgers' Association. He has the name not quite right. It is called the International Fiscal Association. It meets and it passes resolutions —the last one that it passed was on 18th May, 1960—and it has circulated every accountant hon. Member on both sides of the House of Commons with that resolution.

Mr. Mitchison

An arrow shot at random sometimes hits the mark, and this seems to be such a case. My hon. Friends and I would like to know—probably hon. Members on both sides of the Committee would like to know—what has been happening about this and what the seriousness of the matter is; for example, whether the Financial Secretary has ever heard of the interesting body which has just been referred to by my hon. Friend the Member for Gloucester (Mr. Diamond) or whether this is, in fact, pure lucubration by the Treasury—that is, consideration of the possibilities without any instances. The second question that I want to ask is, I think, tolerably clear. Am I right in supposing that, whatever the origin of this Amendment—this important Amendment, I agree—it did not originate out of discussions in Committee?

Sir E. Boyle

On the hon. and learned Gentleman's second point, I think he is quite correct in this instance. We had a fairly full debate on the Question, "That the Clause stand part of the Bill" —it was then Clause 25—and I do not remember any hon. Member on either side raising the point.

My answer to the question about how long this racket has been going on is that I do not know, but I said in Committee that if we did not have this Clause I was satisfied that a good many millions of pounds of revenue— I cannot be more specific than that—would be at stake. I can add two things to that. First, if we did not have the Amendment which I have moved I have not much doubt that the few people—the relatively few people—who have been exploiting the device at which the Clause is aimed would soon start to circumvent its provisions either by carrying out the transaction through associates overseas or by themselves setting up an overseas organisation for that purpose.

Lastly, I think it is fair to say that, of all the Clauses on tax avoidance that we have had. this one comes into a rather different category because this is a straight swindle at the expense of the honest taxpayer. It is pretending something to be so when it is not so. I should not hesitate to call this tax evasion rather than just tax avoidance. It is manufacturing a dividend in order to get a totally unfair and wrong tax advantage and milking the Revenue.

I say those words because I believe we have taken pretty powerful steps here to bring the racket to an end, but I can assure the Committee that if there is any question of the provisions of the Clause being circumvented I have no doubt that whoever is Chancellor of the Exchequer in a future year will wish to make even more sure that the Clause is watertight, and I am sure that in doing so he will have the support of the whole Committee.

Mr. Mitchison

Will he do it retrospectively?

Sir E. Boyle

I should not like to give any undertaking on that score.

8.15 p.m.

Mr. Ede

I think it is worth while drawing attention to the actual operations of the body to which my hon. Friend the Member for Gloucester (Mr. Diamond) alluded. He has handed to me the document which he has received. It is headed "The International Fiscal Association", and in a covering letter the people writing to him describe this as the United Kingdom Branch, and their address is 122, Leadenhall Street. London, E.C.3.

They have sent him what they describe as: …a copy of the resolution passed at the Annual General Meeting of the United Kingdom Branch on 19th May, 1960: 'This meeting of the United Kingdom Branch of the International Fiscal Association (a) deplores the terms of certain Clauses of the current Finance Bill which purport to convert what would otherwise be capital into income for the purposes of the Income Tax Acts and of Clauses such as Clause 26. … which is the one we are now discussing—

The Temporary Chairman

Order. I let the right hon. Gentleman proceed to ascertain whether I could link what he was saying and reading with the Amendment, but I find it rather difficult to do so.

Mr. Ede

Perhaps, Mr. Blackburn, I may be allowed to allude to this on the Question, "That the Clause stand part of the Bill".

Mr. Mitchison

On a point of order, Mr. Blackburn. Is not my right hon. Friend producing something which is at any rate getting very near the mischief aimed at by the Amendment? The mischief aimed at is, not to put it too high, an international arrangement to dodge taxes in this particular way. I understood my right hon. Friend to be producing a circular from a body which appeared to be engaged or to be likely to be engaged in something of the sort. I am sure he would not wish to press it too far, but perhaps an allusion of that sort might be admissible.

The Temporary Chairman

I allowed the right hon. Gentleman to proceed for some time in the hope that I should be able to link what he was saying with the Amendment which we are discussing, but I am afraid that I found it impossible, and that is why I stopped him.

Mr. Ede

I have no grievance, Mr. Blackburn.

Amendment agreed to.

Sir E. Boyle

I beg to move, in page 24, line 5, at the end to insert: broker" means a member of a stock exchange in the United Kingdom other than a jobber The Amendment is merely consequential on the new subsection (5).

Mr. Mitchison

What is a "jobber"? Is he defined? Is he "a member of a stock exchange in the United Kingdom other than a broker"?

Sir E. Boyle

The Amendment adds to the definition subsection by simply defining a "broker", that is to say: …a member of a stock exchange in the United Kingdom other than a jobber. As to the question about how a "jobber" is defined, I should require judicial notice of the question.

Mr. Diamond

Perhaps I may help the hon. Gentleman. All he requires to do is to look at the Bill, for Clause 26 (5) says: 'jobber' means a member of the London Stock Exchange who is recognised by the committee thereof as carrying on the business of a jobber".

Sir E. Boyle

I am sorry.

Amendment altered to.

Motion made, and Question proposed, That the Clause, as amended, stand part of the Bill.

Mr. Diamond

I am most grateful for the words, and the feeling behind them, used by the Financial Secretary in connection with what he rightly called "this racket". The only thing I cannot understand about this Clause is that being a racket and being something, as the Attorney-General said, more than tax evasion—I believe he said that when winding up the Second Reading debate—

The Attorney-General

There is no need for the hon. Gentleman to look it up. I cannot remember exactly what I said in that speech, but if it will satisfy him I will say it now.

Mr. Diamond

I am very grateful to the right hon. and learned Gentleman. This is something quite outside the normal realm of tax avoidance and tax avoidance legislation which we have been discussing. I cannot understand why the perpetrators of this racket cannot be got at by common law or be prosecuted for doing something which seems to the ordinary man in the street and to Members on both sides of the Committee to be a plain fraud. I appreciate that all these Amendments are necessary to stop Income Tax avoidance, but in this case something more than fiscal legislation is required—prosecution is needed.

The Attorney-General

I do not think that it is, for this reason: in the simple case the person who manufacturers the dividend is not the person who claims back the tax from the Inland Revenue. He gets his profit on the price he gets for the shares, having paid them cum dividend, cum manufactured dividend. The person who obtains money from the Inland Revenue is the recipient. I do not think that it is possible—though I sympathise with the hon. Gentleman, and there is no reluctance to prosecute in cases of fraud where circumstances warrant it—that a prosecution would lie here.

Mr. Diamond

I assume that the right hon. and learned Gentleman is saying that these cannot be caught as a conspiracy—one person conspiring with another to defeat the Inland Revenue. I understand that these transactions do not take place until two people get together.

The Attorney-General

Proof of conspiracy is always difficult, depending on the evidence available. I would not hold out any hopes of evidence forthcoming to warrant a prosecution of that kind.

Mr. Mitchison

I shall say nothing in general about the Clause, but one small point is rather doubtful. It says that a broker …means a member of a stock exchange in the United Kingdom, other than a jobber;". and that a jobber …means a member of the London Stock Exchange who is recognised by the committee thereof as carrying on business of a jobber;". I do not know if there is such a thing as a provincial jobber. If there is, he now becomes a broker because he is not a member of the London Stock Exchange recognised by its committee as carrying on business as a jobber. It is possible that the Government may be able to answer that point now. It depends on the way in which provincial Stock Exchanges carry on their business. If there are provincial jobbers, there is real point in this and it could be set right by an Amendment put down today and dealt with on Report tomorrow.

Sir E. Boyle

This point came up on Committee. We discussed it on Clause 25, and I cannot add to what I said then when dealing with provincial stock exchanges—that a dealing broker dues the same work as a jobber of the London Stock Exchange. I will check up on that point again, but I cannot go further at the moment.

Mr. Mitchison

That would be all right if it were the same point, but it is not. The hon. Gentleman has just put in an Amendment which says that a broker is … a member of a stock exchange in the United Kingdom other than a jobber; When we turn to see what a jobber is, he is defined in appropriate terms relating only to the London Stock Exchange. Accordingly, every member of a provincial stock exchange must, on these two definitions—the Attorney-General will see what I mean—be a broker. It is possible that he is, and that the use of the phrase "dealing broker", or something of that kind, covers it. I mention this point because we are all anxious that this Clause should be effective, and if there is such a thing as a provincial jobber, then these two definitions between them need alteration. If there is not such a thing, the question does not arise. If there is, the question should be dealt with tomorrow.

Mr. Diamond

My hon. and learned Friend's point is extremely valid and well made. The matter occurred to me and I made exhaustive inquiries. I was told that there was no provincial stock exchange on which there was a jobber.

Question put and agreed to.

Clause, as amended, ordered to stand part of the Bill.