§ Mr. Peter Walker
I beg to move, Amendment No. 77, Clause 36, in page 42, line 12, at end insert:(c) if at the time that the said conditions cease to be satisfied, a loss would have been incurred as a result of transferring the proceeds of the disposal or part thereof to the United Kingdom, the claimant shall be entitled to have that loss deducted from any chargeable gain which arose from the disposal including that arising on any other transfer to the United Kingdom of part of the proceeds of disposal.I apologise for disturbing the love-hate duet between the hon. Member for Manchester, Cheatham (Mr. Harold Lever) and the Chief Secretary. I can only believe the hon. Member tries to make up with praise for the unpopularity that Treasury Ministers currently suffer throughout the country.
This Amendment to Clause 36, which deals with relief in respect of delayed remissions of gains, speaks for itself. It is an endeavour to see that if, as a result of having to remit, a loss has occurred that loss can be allowed for. 1853 Such losses can occur due to specific currency regulations of countries and certain tax regulations of countries when the proceeds of a disposal are taken out of the country. This is purely an endeavour to meet that point, which I hope the Government will find acceptable.
§ Mr. Diamond
I can answer the hon. Member by saying that I do not think his Amendment, except as to one small point, is necessary. As to that one small point, I do not think it would be right that the Government should be asked to meet it. In general terms, I would remind the House that currency is itself a chargeable asset and, therefore, if there is either profit or loss on realising currency, it is a chargeable gain or loss which can be set off against the other transaction which is being referred to. Therefore, as far as I have gone, it is unnecessary to introduce an Amendment.
The only thing the hon. Member's Amendment does, which I do not think I could ask the House to accept, is to allow the possibility of a future loss where foreign currency is not exchanged immediately. I suggest the attitude of the Government is right there, because there are two separate transactions: one is the main transaction, and the second is the decision of the vendor or the person entering into the transaction to defer until some future date the decision whether or not he makes a currency exchange.
In those circumstances, I hope the hon. Member will not press his Amendment.
§ Mr. Peter Walker
I am grateful to the Chief Secretary and recognise the point about the currency. I would naturally presume the factor of time of disposal would be treated reasonably by the Revenue. In view of those assurances, I beg to ask leave to withdraw the Amendment.
§ Amendment, by leave, withdrawn.