HC Deb 23 May 1963 vol 678 cc657-73
Sir John Barlow (Middleton and Prestwich)

I beg to move, in page 46, line 44, at the end to add: (2) Section 23(1) of the Finance Act 1957 shall also apply so that the same results shall follow in respect of a subsidiary company not resident in the United Kingdom but trading wholly outside the United Kingdom, as would now follow if the trade of that company was carried on by a company resident in the United Kingdom, and section 35 of the said Act shall apply in respect of dividends from a subsidiary company as defined above as it now does to the overseas trading income; and the provisions of Schedules 5 and 6 shall apply accordingly. It will be remembered that the idea of the overseas trade corporations was started about six years ago. At that time it was obvious that this was entirely new legislation for the Treasury, and, plainly, it had to be very careful to see how it would work. For that reason, it was rather circumscribed, and it must be regarded as a pilot scheme. It was for companies registered in the United Kingdom with branches abroad, and it did not cover non-resident subsidiaries which were abroad or in this country.

The result was that the overseas trade corporation experiment as intended by the Royal Commission on Taxation, namely, that it should apply to all businesses outside the United Kingdom, was not achieved. In view of the experience of the last six years, I suggest that the time has arrived when this extension could be made.

The Treasury has great experience of these companies—I believe that they number 836—and, obviously, it can see fairly easily how any further extension would work. If this extension were allowed, it would help very much our balance of payments, and it would help the transfer of funds from one part of the Commonwealth to another, which is not provided for at present.

If my right hon. Friend the Chancellor of the Exchequer has any criticism of this suggestion, it may be that there is a risk of tax avoidance. Since the cost of the overseas trade corporation companies has been much lower than was originally estimated, and in view of the great knowledge and experience about these companies which the Treasury has gained, I believe that there is very little risk of that.

As I have said, it is probable that this Amendment will help the flow of funds from one Commonwealth country to another and will also encourage non-sterling companies to register in this country and carry on business, which will be of great benefit to this country and to the Commonwealth countries involved.

Mr. Stanley R. McMaster (Belfast, East)

I support the Amendment, which has been so admirably moved by my hon. Friend the Member for Middleton and Prestwich (Sir J. Barlow). I do not wish to repeat the argument which he has clearly and lucidly adduced, but I should like to add one point.

The fear of any loss through tax avoidance as a result of accepting the Amendment should be counterbalanced by the fact that many overseas trade corporations face competition from similar companies which are resident in other European countries, where they have a greater advantage than British overseas trade corporations.

To accept the Amendment would help to put them on an equal footing with such companies which are registered, particularly, in France, Germany and Italy. It would be of considerable advantage to them if their foreign subsidiaries could transfer their profits from one overseas country to another and would help to build up British interests abroad, which must be to the long-term benefit of this country.

The Financial Secretary to the Treasury (Mr. Anthony Barber)

It is not easy for those who have not followed our debates in previous years to appreciate the significance of this Amendment. I think that my hon. Friend the Member for Middleton and Prestwich (Sir J. Barlow), who introduced it, has set out clearly what he has in mind. I should like to assure him that, although the Amendment appeared on the Notice Paper only a couple of days ago, this was one of the aspects of the overseas trade corporation scheme which my right hon.

Friend considered before reaching his conclusions about the Budget.

As my hon. Friend will realise, the principal object of the overseas trade corporation scheme was to meet the complaint that the high rates of United Kingdom tax made it difficult for United Kingdom resident companies trading overseas to compete with local companies or with companies resident in third countries which paid tax at a lower rate or got some form of special tax relief.

While the scheme was designed mainly to give relief to trading companies, it also gives certain relief to holding companies. A United Kingdom company which does not itself carry on any trade, but which is the parent of one or more trading overseas trade corporations, can, subject to certain conditions, itself qualify as an overseas trade corporation, and, if it does, it is exempt from Income Tax and Profits Tax on any dividend from a subsidiary overseas trade corporation and can, without becoming liable, use such a dividend to finance, by grant or by loan, another subsidiary overseas trade corporation.

This covers the point in the case of resident companies switching between one subsidiary company and another through the medium of the parent company, which, I understand, from the two speeches to which we have listened, it is desired to extend to the case of those subsidiary companies which are not resident in the United Kingdom.

There are a number of points that I could make about the Amendment, but I do not think that my hon. Friend would wish me to go into details about drafting, and I need not remind the Committee of the object, because it has been so clearly and briefly put by my hon. Friend.

My hon. Friend may or may not know that we have had discussions with industry about proposals similar to that which is embodied in the Amendment. We asked the representatives of industry who met us to discuss these proposals, whether they could furnish us with any actual example of cases where desirable development in an overseas territory had been held up because of the absence of what might be called the overseas trade corporation switching facilities to which I have referred. They were not able to provide us with any such examples, although it does not necessarily follow that there is none.

They referred to cases in which money was left in the country of origin when it might have been more usefully employed elsewhere. But that is not quite the same thing. I am not saying for one moment that there are not considerable arguments in favour of what my hon. Friend has put forward, and he will recall that we have discussed much the same point in previous years.

A further matter to which I should draw the attention of the Committee is that the tax at issue in the case envisaged by my hon. Friend is not the full extent of the United Kingdom taxation on dividends received by United Kingdom companies, because in the ordinary way these funds will have borne tax in the country in which they have been earned, and double taxation relief would be available to the parent company. In many cases the tax at issue may not be more than a small percentage of the funds being transferred.

4.15 p.m.

Before this Amendment appeared on the Notice Paper, we considered the whole of the overseas trade corporation scheme, including this aspect. I must regretfully tell my hon. Friend that, in our view, the arguments against these proposals have lost none of their weight. In the first place, the whole object of the overseas trade corporation scheme is to benefit a resident company. The retention by companies operating overseas of their United Kingdom residence benefits this country in a number of ways which are quite unconnected with taxation. I can give my hon. Friend examples if he wishes, but I hope that it will suffice to say that it was one of the merits claimed for the scheme that it would help to prevent the migration of United Kingdom companies to other countries.

Secondly, I should like to remind the Committee that the non-resident company of which my hon. Friend is speaking is not by the overseas trade corporation scheme made any worse off than it was before and still has certain tax advantages as compared with the overseas trade corporation. For example, it is not liable to Profits Tax on its investment income whether arising in this country or overseas. It is not liable to Income Tax on overseas investment income or on income from War Loan and certain other British Government securities.

The overseas trade corporation, on the other hand, is liable to Income Tax and Profits Tax on the whole of its investment income. Moreover, distributions made by non-resident companies on liquidation constitute capital receipts in the hands of shareholders and are not liable to United Kingdom tax. Distributions on liquidation by overseas trade corporations, on the other hand, so far as they come out of exempt trading profits and do not represent the repayment of the original capital, are chargeable to Income Tax in the hands of the liquidator.

My hon. Friend referred to the fact that the admission of non-resident subsidiaries might involve some risk of tax avoidance. It is true to say that for any scheme offering adequate safeguards, which would be necessary if we were to do as my hon. Friend suggests, the legislation would be very complicated indeed. I was reminded before I came into the Chamber that my right hon. Friend the Chancellor of the Exchequer, when he was Paymaster-General, in 1959, spoke about the point which my hon. Friend has raised again this afternoon and dealt at some length with the difficulty of preventing avoidance.

I think, from what little I know of the details of the subject matter, that my hon. Friend has probably got a point in saying that, from the experience which we have gained over the years, it would be easier now to deal with the anti-avoidance provisions than when the scheme was introduced. I hope from what I have said that the Committee will appreciate that that is not the only point on which we feel considerable doubt in connection with this proposal.

I assure my hon. Friend that his suggestion, which would, of course, involve a basic change in the overseas trade corporation scheme, was carefully considered before my right hon. Friend framed his Budget proposals and we have looked at it again since his Amendment appeared on the Notice Paper. But I fear that I cannot advise the Committee to accept the principle which my hon. Friend seeks, and I hope that on that account he will not press his Amendment. If that were not enough, I would remind my hon. Friend, without troubling him with the details, that I hope he will accept it from me that his Amendment is not in any event adequate to deal with the avoidance problem which my hon. Friend frankly admitted would have to be dealt with and which is inherent in the proposal about which he has spoken.

Sir J. Barlow

In view of my hon. Friend's explanation—which is not entirely satisfactory, but I appreciate some of the difficulties—I beg to ask leave to withdraw the Amendment.

Amendment, by leave, withdrawn.

Question proposed, That the Clause stand part of the Bill.

Mr. Mitchison

I am sorry, but I must ask the Government again to be so good as to explain, first, why the original proviso was put into Section 23 of the Finance Act, 1957, and secondly, what change of circumstances has now caused the Government to recommend its removal. Will they, at the same time, indicate the financial effect of the proposed removal?

Mr. Barber

As the /ion. and learned Member will appreciate, the Clause is of limited application. I explained its purpose on Second Reading. Suffice it to say that the object is to abolish a rule which is set out in Section 23 of the 1957 Act and which, in effect, denies the status of an overseas trade corporation to certain holding companies.

The Clause is the substance of a provision to meet a point which has been made by my hon. Friend the Member for Portsmouth, Langstone (Mr. Stevens). Under the 1957 Act, a United Kingdom company can, in certain circumstances, with which we are all familiar, qualify as an overseas trade corporation. If it qualifies, it is freed from Profits Tax on the profits of its trade and it is not required to pay Income Tax on them either as long as they are withheld from distribution.

A company with a trade of its own can enjoy overseas trade corporation status even when it possesses one or more subsidiaries in the United Kingdom which are not themselves overseas trade corporations. To prevent such a parent company from using the trading profits, which are exempted in its hand while undistributed, for the purpose of financing either through loans or grants the operations of a subsidiary carrying on a trade within the United Kingdom, the 1957 Act contains a safeguarding provision which imposes liability on an overseas trade corporation in respect of exempt trading income advanced by way of loans or grant to any associated company which is not itself an overseas trade corporation.

A company which has no trade of its own can also secure recognition as an overseas corporation if it has one or more subsidiaries which are trading as overseas trade corporations. The proviso to Section 23(1) of the 1957 Act, to which the hon. and learned Member for Kettering (Mr. Mitchison) has referred, disqualifies a holding company if it possesses any subsidiary which is resident in the United Kingdom but which is not itself an overseas trade corporation.

The hon. and learned Gentleman asked why the proviso was originally inserted in the 1957 Act. It was inserted as a long-stop to prevent avoidance of taxation. If the provisions which impose tax on the making of a loan or grant to an associated company, to which I referred a few moments ago, are adequate, there is no need for the long-stop. When the overseas trade corporation scheme was first devised, those at the Treasury at that time thought that it would be sensible to err on the side of safety and did not feel that we could safely dispense with the proviso, to which exception has been taken on a number of occasions since.

Mr. Mitchison

By whom was exception taken?

Mr. Barber

By those in industry. I was coming on to explain that there may well be circumstances which force an overseas trade corporation to cease trading, with the result that its own loss of status would bring disqualification upon the parent as a result of the operation of the proviso.

The danger can best be illustrated if one considers a trading subsidiary which, under threat of, say, expropriation in an overseas territory, has no prudent course open to it but to dispose of its trade to local interests. If the subsidiary ceased to trade, it would thereby bring disqualification on the parent com- pany, which would become liable to tax forthwith on the entire undistributed balance of the exempt trading income, including dividends, from all its overseas trade corporation subsidiaries which it had enjoyed since it first qualified as an overseas trade corporation. It will be apparent to everybody that whatever might be the rights and wrongs of dispensing with the proviso, this would have serious financial consequences for the parent company concerned.

Originally, we thought it necessary to include the proviso because we felt that unless we did so, there would be dangers of unscrupulous people seeking to avoid tax. Since then, we have had more experience of the working of the scheme and we have reached the conclusion that the existing provision—[Interruption.] I do not know why the hon. Member for Cardiff, South-East (Mr. Callaghan) shakes his head. He was away all last week. He comes back and immediately says, "No, no, no."

We have considered this matter carefully. My right hon. Friend would certainly not have dispensed with the proviso unless he was satisfied that the existing provisions and the way the scheme had worked out were adequate. We have reached the conclusion that the existing provisions without automatic disqualification in such a case are adequate.

I hope that for the reasons I have given the Committee will agree that the Clause is reasonable and will go quite a long way to prevent companies which otherwise might in all innocence be faced with serious financial penalties from being put in that position.

Mr. Mitchison

Will the hon. Gentleman answer my question about the financial effect?

Mr. Barber

I am advised that the result is not so much to sacrifice revenue, but to relieve those engaged in overseas business from the necessity of so arranging their affairs as to avoid falling into a particular taxation pitfall. Consequently, there will be no significant effect upon the Exchequer.

Mr. Mitchison

As we remember, this proviso was put in as a safeguarding provision against tax avoidance. When the original proposals contained in the 1957 Finance Act were before the Committee, we from this side pointed out again and again that those proposals were full of opportunities, so it seemed to us, for tax avoidance. In this case, to the best of my recollection—and I have referred to the debates at the time—the Treasury included this long-stop on their own without being obliged to do it. It was a long-stop of general application. It was what should and what should not be a very privileged body, an overseas trade corporation.

The balls, or some of them, have, no doubt, been stopped, but the Treasury is in no position to tell us which were stopped by the long-stop and which by the wicket-keeper. Therefore, we have no indication of how effective the wicketkeeper has been or whether it is wise to remove the long-stop.

I do not want to go into the matter in great detail, but, when we are given the instance which the Financial Secretary has put before us, I do not see the great hardship that is indicated. The companies concerned have had the benefit of an exceptional concession that was given to them under certain conditions in the Act. We were told, rightly, that they could have made provisions which would have saved them any trouble in the event indicated. All that the Government's proposal does is to prevent them from taking the trouble to make the necessary provisions.

We are told that there will not be any revenue effect. That depends, however, upon who stops the bowling—and it remains to be seen. There are so many —I do not know whether to call them balls or wides; I would almost have said side slips, but I do not think those are bowled. So many funny things are going on in connection with overseas trade corporations that not only were we justified in our objections at the time, but they arose out of the recommendations of the Royal Commission.

4.30 p.m.

Those recommendations were very cautious and limited. They were dissented to by a minority of the Royal Commission at the time. They did not deal with the question of subsidiaries, which is far the most difficult part of all this. I should have thought that, if the Treasury felt that there was some reason for making special provision for the particular circumstances the hon. Gentleman has indicated, it was not a case of removing the long-stop, but of making some other and more appropriate provision for what is required.

If the hon. Gentleman expects us to support this Clause when the object is to remove a tax avoidance provision, to widen the scope of an arrangement we have always regarded with a great deal of criticism, we shall have to disappoint him on this occasion.

Mr. Barber

I am sure that, in fairness, the hon. and learned Gentleman will agree that, if the other provisions in the scheme to which I referred earlier are adequate to deal with the matter—in other words, those provisions which impose tax on the making of a loan or grant to an associated company—he will be the first person to say that we need not have the proviso which it is now sought to remove from the 1957 Act.

If it turns out, contrary to our expectations, that the proviso is needed after all, I am sure that I can give an assurance to the Committee, on behalf of my right hon. Friend, that we will deal with the matter. Of course, in view of what the hon. and learned Gentleman has said, we will keep the matter under review, but we would not have taken this step unless we really thought it a fair thing to do and that we had sufficient safeguards in the original legislation.

Mr. Mitchison

We are anxious to save time on this matter. All we wish to say is that we prefer the Treasury when it is trying to safeguard against evasions, as it was in 1957, to the Treasury of 1963, which, apparently, is trying to save taxpayers a certain amount of trouble in arranging their affairs.

Sir J. Barlow

I welcome this Clause and regard it as a long-lost friend—so long-lost that it has almost been forgotten. In June, 1957, the then Economic Secretary, turning down this proposal, said that it …raises extremely complex…points… my right hon. Friend… is studying this matter with full sympathy…we are giving this very complex and difficult problem sympathetic consideration."—[OFFICIAL REPORT, 26th June, 1957; Vol. 572, c, 308.] It has been hidden in the archives for six years, so it is all the more welcome now. I hope that the principle of the Amendment which I have just failed to get adopted, will not be lost sight of for the next six years.

Mr. Geoffrey Stevens (Portsmouth, Langstone)

I am grateful to my right hon. Friend the Chancellor for accepting the proposals on this very valuable point which my hon. Friend the Member for Middleton and Prestwich (Sir J. Barlow) and I have been hammering away at all this time. I believe that the removal of this long-stop will enable British trade to do more business overseas, and that will be a good thing for all of us. I am glad that he has done it this time.

But one point puzzles me. If it is right in May, 1963, that this potential cause of disqualification should be removed, would it not have been equally right, after all, in 1957? The Clause as drawn has no retrospective effect. If it is right today, surely the Clause should be redrafted to have effect back to 1957.

Mr. Barber

I think that there would be grave objections to doing as my hon. Friend the Member for Portsmouth, Langstone (Mr. Stevens) suggests. It would certainly lead to very serious practical difficulties. The treatment for both Income Tax and Profits Tax purposes of a holding company qualifying as an overseas trade corporation is quite different from that of a non-overseas trade corporation holding company. If we were to do as my hon. Friend suggests, it would be necessary to revise the whole of these companies' liabilities in the past six years.

I do not want to get too far into this, but the matter does not even rest there. The holding companies in question may well have made distribution of profits by way of dividends during these six years on the basis that they were not overseas trade corporations, and the recipients of those distributions will quite properly have been assessed to tax on the assumption that that basis was correct. If we were now to make this Clause retrospective, obviously different tax consequences for those who have received dividends would ensue. There would be grave practical difficulties, apart from the question of principle, involved in doing as my hon. Friend suggests.

Mr. James Callaghan (Cardiff, South-East)

This is not good enough. The whole question of overseas trade corporations, after six years' experience, needs reviewing in detail to see how far this system is profitable to Britain. Profitability was its justification originally. We need much more information. As far as I can see, these things are all available even when money is remitted back to this country. I believe that a great deal of this money will not qualify and return to this country. For this reason, I am very much against any extension of this nature.

I believe that the hon. Member for Portsmouth, Langstone (Mr. Stevens) is leaving the House at the next election. We shall be very sorry to see him go. He has always brought a great deal of dignified learning and knowledge to our discussions on taxation. But perhaps it is because he is leaving us, and is considering this purely from the point of view of what he believes to be right in the circumstances, that he does not understand why it is being done in 1963 but could not be done in 1957, according to the Government. The simple explanation is that there is an election coming. Whether it be expansion of corporations or remission of Stamp Duty-—

The Chairman

Order. I hope that the hon. Gentleman will not go further. We are discussing whether Clause 43 should stand part of the Bill.

Mr. Callaghan

I am discussing the reasons for introducing this provision, Sir William. The question was asked why it was introduced, and I was giving the answer.

It was introduced to sweeten the City and get a few more subscriptions to Tory Party funds. It makes nice women of a number of companies who have been arranging their affairs not illegally, but not with that degree of purity we would like to see. We all know that. This provision is designed to further Tory Party funds, and as we have no wish to assist them to get more money, we will divide against this Clause.

Mr. McMaster

I rise to say how much I disagree with the remarks made by the hon. Member for Cardiff, South-East (Mr. Callaghan). There are many ways in which this country can be benefited by this provision in addition to the direct remission of money from trading subsidiaries abroad. Not only can their profits be used by other businesses abroad ordering goods from Britain, but, also, British interests are extended and, therefore, when such companies, and others, a re buying capital equipment the money is much better spent here than in some of our foreign competitors. That is just one reason why I support this extension of the rule, which was introduced six years ago.

I return to the point I made earlier. Many of our trading competitors are much more generous with their overseas trading corporations than this country has been heretofore. I support this extension and I should like the Government to reconsider the original Amendment in the hope that, as with the Amendment introduced by my hon. Friends six years ago, in time it will he accepted by the Government, because it is to the benefit of this country to build up its overseas trading interests.

Mr. J. T. Price (Westhoughton)

I am not so much concerned with the academic arguments advanced in favour of the proposed change as with the practical effect. I remind the Committee that in the debates on the 1957 Finance Act I had a considerable argument with the then Financial Secretary to the Treasury, now the right hon. Gentleman the Minister of Health, who, in reply to my observations about relief given to overseas trade corporations, said that it would

make a valuable contribution to the balance of payments and replenish some of the losses otherwise suffered by adverse conditions of trade.

In fact, exactly the opposite has occurred. During that argument, I asked one or two questions which were germane to the issue and are even more germane now. What purpose is served in the country's economic performance if capital invested in overseas trade corporations does not provide work for British workers, or return to the parent company in Britain the profits earned, if any, by those operations overseas?

These are weighty considerations. Last year, to check what had happened, I put some Questions to Treasury Ministers—I will not weary the Committee with the references—to elicit what losses had been suffered by the Treasury as a result of the loss of the overseas trade corporation Clause. I was told that in 1961 it was £16 million and about £11 million in 1960 and figures of that order for other years. That does not support the proposal to extend these powers and I think that my right hon. and hon. Friends are right to insist that this is a matter of principle upon which the Government have not made their case and that we should register our protest in the Division Lobby.

Question put, That the Clause stand part of the Bill: —

The Committee divided: Ayes 193, Noes 128.

Division No.121.] AYES [4.43 p.m.
Allason, James Butler, Rt. Hn. R.A. (Saffron Walden) Finlay, Graeme
Arbuthnot, John Carr, Robert (Mitcham) Fletcher-Cooke, Charles
Atkins, Humphrey Chichester-Clark, R. Fraser, Rt, Kn. Hugh(Stafford &Stone)
Awdry, Daniel (Chippenharm) Clark, Henry (Antrim, N.) Fraser, Ian (Plymouth, Sutton)
Balniel, Lord Clark, William (Nottingham, S.) Galbraith, Hon. T. G. D.
Barber, Anthony Cleaver, Leonard Gammons, Lady
Barlow, Sir John Cooper-Key, Sir Neill Gardner, Edward
Barter, John Cordeaux, Lt.-Col. J. K. Glyn, Sir Richard (Dorset, N.)
Batsford, Brian Corfield, F. V. Goodhew, Victor
Beamish, Col. Sir Tufton Coulson, Michael Grant-Ferris, R.
Bell, Ronald Courtney, Cdr. Anthony Grimond, Rt. Hon. J.
Bennett, Dr. Reginald (Cos & Fhm) Craddock, Sir Beresford (Spelthorne) Grosvenor, Lt.-Col. R. G.
Berkeley, Humphry Critchley, Julian Gurden, Harold
Biffen, John Crosthwaite-Eyre, Col. Sir Oliver Hail, John (Wycombe)
Biggs-Davison, John Curran, Charles Hamilton, Michael (Wellingborough)
Bingham, R. M. d'Avigdor-Goldsmid, Sir Henry Harrison, Brian (Maldon)
Bishop, F. P. Digby, Simon Wingfield Harrison, Col. Sir Harwood (Eye)
Black, Sir Cyril Donaldson, Cmdr. C. E. M. Harvey, Sir Arthur Vere (Maccleef'd)
Bossom, Hon. Clive Drayson, G. B. Heald, Rt. Hon. Sir Lionel
Bowen, Roderic (Cardigan) du Cann, Edward Henderson, John (Cathcart)
Boyd-Carpenter, Rt. Hon. John Duncan, Sir William Hiley, Joseph
Boyle, Rt. Hon. Sir Edward Eiliot, Capt. Walter (Carshalton) Hill, Dr. Rt. Hon. Charles (Luton)
Brown, Alan (Tottenham) Emmet, Hon. Mrs. Evelyn Hill, Mrs. Eveline (Wythenshawe)
Bullard, Denys Errington Sir Eric Hill, J. E. B. (S. Norfolk)
Bullus, Wing Commander Eric Farey-Jones, F. W. Hirst, Geoffrey
Burden, F. A. Fell, Anthony Holland, Philip
Hopkins, Alan Marshall, Douglas Smith, Dudley (Br'tnf'd & Chiswick)
Hornby, R. P. Marten, Neil Smithers, Peter
Hornsby-Smith, Rt. Hon. Dame P. Matthews, Gordon (Meriden) Smyth, Rt. Hon. Brig. Sir John
Howard, Hon. G. R. (St. Ives) Mawby, Ray Spearman, Sir Alexander
Howard, John (Southampton, Test) Maxwell-Hyslop, R. J. Stevens, Geoffrey
Hughes Hallett, Vice-Admiral John Maydon, Lt.-Cmdr. S. L. C. Steward, Harold (Stockport, S.)
Hughes-Young, Michael Mills, Stratton Studholme, Sir Henry
Hurd, Sir Anthony Morgan, William Talbot, John E.
Hutchison, Michael Clark Morrison, John Tapsell, Peter
James, David Nabarro, Sir Gerald Taylor, Frank (M'ch'st'r, Moss Side)
Jenkins, Robert (Dulwich) Nicholson, Sir Godfrey Teeling, Sir William
Johnson, Dr. Donald (Carlisle) Nugent, Rt. Hon. Sir Richard Temple, John M.
Johnson Smith, Geoffrey Orr, Capt. L. P. S. Thatcher, Mrs. Margaret
Jones, Rt. Hn. Aubrey (Hall Green) Page, Graham (Crosby) Thompson, Sir Kenneth (Walton)
Kaberry, Sir Donald Page, John (Harrow, West) Thompson, Sir Richard (Croydon, S.)
Kerr, Sir Hamilton Pannell, Norman (Kirkdale) Thorpe, Jeremy
Kershaw, Anthony Pearson, Frank (Clitheroe) Touche, Rt. Hon. Sir Gordon
Kirk, Peter Peel, John Turner, Colin
Kitson, Timothy Pickthorn, Sir Kenneth Turton, Rt. Hon. R. H.
Lagden, Godfrey Pitman, Sir James Tweedsmuir,Lady
Lancaster, Col. C. G. Pitt, Dame Edith Vaughan-Morgan, Rt. Hon. Sir, John
Leavey, J. A, Pott, Percivall
Leburn, Gilmour Price, David (Eastleigh) Vickers, Miss Joan
Legge-Bourke, Sir Harry Prior, J. M. L. Wade, Donald
Linstead, Sir Hugh Prior-Palmer, Brig. Sir Otho Wakefield, Sir Wavell
Longbottom, Charles Proudfoot, Wilfred Walder, David
Loveys, Walter H. Pym, Francis Walker, Peter
Lubbock, Eric Quennell, Miss J. M. Walker-Smith, Rt. Hon. Sir Derek
Lucas, Sir Jocelyn Rawlinson, Sir Peter Ward, Dame Irene
Lucas-Tooth, Sir Hugh Redmayne, Rt. Hon. Martin Williams, Dudley (Exeter)
McAdden, Sir Stephen Rees, Hugh Williams, Paul (Sunderland, S.)
McLaren, Martin Rees-Davies, W. R. Wilson, Geoffrey (Truro)
Maclay, Rt. Hon. John Renton, Rt. Hon. David Wise, A. R.
Maclean,SirFitzroy(Bute&N.Ayrs) Ridley, Hon. Nicholas Woodhouse, C. M.
Macleod, Rt. Hn. Iain (Enfield, W.) Ridsdale, Julian Woollam, John
McMaster, Stanley R. Robson Brown, Sir William Worsley, Marcus
Macpherson, Rt. Hn. Niall(Dumfries) Russell, Ronald
Maltland, Sir John Sharpies, Richard TELLERS FOR THE AYES:
Marlowe, Anthony Shaw, M. Mr. Gordon Campbell and
Marples, Rt. Hon. Ernest Skeet, T. H. H. Mr. MacArthur.
NOES
Albu, Austen Hale, Leslie (Oldham, W.) Morris, John
Allaun, Frank (Salford, E.) Hannan, William Moyle, Arthur
Allen, Scholefield (Crewe) Harper, Joseph Neal, Harold
Awbery, Stan (Bristol, Central) Hart, Mrs. Judith Noel-Baker, Francis (Swindon)
Bence, Cyril Hayman, F. H. Oram, A. E.
Bennett, J. (Glasgow, Bridgeton) Healey, Denis Pannell, Charles (Leeds, W.)
Benson, Sir George Henderson, Rt. Hn.Arthur(RwiyRegis) Pavitt, Laurence
Blackburn, F. Herbison, Miss Margaret Peart, Frederick
Bowden, Rt. Hn. H. W. (Leics, S.W.) Holman, Percy Popplewell, Ernest
Boyden, James Houghton, Douglas Prentice, R. E.
Braddock, Mrs. E. M. Hoy, James H. Price, J. T. (Westhoughton)
Bray, Dr. Jeremy Hughes, Cledwyn (Anglesey) Probert, Arthur
Butler, Mrs. Joyce (Wood Green) Hughes, Emrys (S. Ayrshire) Pursey, Cmdr. Harry
Callaghan, James Hughes, Hector (Aberdeen, N.) Randall, Harry
Carmichael, Neil Hunter, A. E. Rankin, John
Castle, Mrs. Barbara Irving, Sydney (Dartford) Reynolds, G. W.
Cliffe, Michael Janner, Sir Barnett Roberts, Goronwy (Caernarvon)
Collick, Percy Jeger, George Robertson, John (Paisley)
Corbet, Mrs. Freda Jenkins, Roy (Stechford) Robinson, Kenneth (St. Pancras, N.)
Cronin, John Jones, Rt. Hn. A. Creech (Wakefield) Ross, William
Crosland, Anthony Jones, Dan (Burnley) Royle, Charles (Salford, West)
Cullen, Mrs. Alice Jones, Elwyn (West Ham, S.) Shinwell, Rt. Hon, E.
Cullen,, Mrs. Alice Kelley, Richard Silverman, Julius (Aston)
Darling, George Kenyon, Clifford Skeffington, Arthur
Deer, George Key, Rt. Hon. C. W. Small, William
Dempsey, James King, Dr. Horace Snow, Julian
Diamond, John Lawson, George Soskice, Rt. Hon. Sir Frank
Dodds, Norman Lewis, Arthur (West Ham, N.) Spriggs, Leslie
Ede, Rt. Hon. C. Mabon, Dr. J. Dickson Steele, Thomas
Edwards, Rt. Hon. Ness (Caerphilly) MacColl, James Stewart, Michael (Fulham)
Edwards, Walter (Stepney) McInnes, James Stonehouse, John
Fernyhough, E. McKay, John (Wallsend) Strauss, Rt. Hn. G. R. (Vauxhall)
Foot, Dingle (Ipswich) McLeavy, Frank Stross, Dr. Barnett(Stoke-on-Trent,C.)
Foot, Michael (Ebbw Vale) MacPherson, Malcolm (Stirling) Swingter, Stephen
Forman, J. C. Mallalieu, E. L. (Brigg) Thomas, George (Cardiff, W.)
Fraser, Thomas (Hamilton) Manuel, Archie Tomney, Frank
Galpern, Sir Myer Marsh, Richard Warbey, William
George, LadyMeganLloyd(Crmrthn) Mayhew, Christopher Wells, William (Walsall, N.)
Ginsburg, David Mendelson, J. J. Willey, Frederick
Gordon Walker, Rt. Hon. P. C. Millian, Bruce Williams, D. J. (Neath)
Grey, Charles Mitchison, G. R. Williams, Ll. (Abertillery)
Willis, E. G. (Edinburgh, E.) Wyatt, Woodrow TELLERS FOR THE NOES:
Wilson, Rt Hon. Harold (Huytod) Yates, Victor (Ladywood) Mr. Redhead and Mr. McCann.
Woof, Robert