HC Deb 21 June 1965 vol 714 cc1358-70
Sir Eric Fletcher

I beg to move Amendment No. 566: In page 100, line 15, at the end to insert: ; and for those purposes the question whether any and, if so what, gain or loss so accrues shall accordingly be determined in accordance with the provisions applicable to income tax chargeable under Case VII of Schedule D and not in accordance with the provisions of Part III of this Act.". If it is convenient, Mr. Grant-Ferris, in moving this Amendment I shall also deal with Amendments Nos. 567, 568, 564 and 565.

The Temporary Chairman (Mr. Grant-Ferris)

I think it would be for the convenience of the Committee to follow that procedure.

Sir Eric Fletcher

These Amendments are all in the nature of clarifying Amendments to make the provisions of Clause 77 even clearer and simpler than at present. Unless the Committee so desires, I shall not explain the precise effect of each of these five Amendments. I imagine that they have been carefully examined by the Opposition. They do not make any substantive change, but are intended to improve the language and are in the nature of clarifying Amendments.

Mr. Peter Walker (Worcester)

We shall be very happy to co-operate with the right hon. Gentleman and take these Amendments together, but that does not necessarily mean that we want no explanation of them. His description of them as clarifying Amendments simplifying the Bill does not amount to an explanation. Amendment No. 566 will make a substantial difference and is not simply a clarifying Amendment.

As the Bill stands without this Amendment losses sustained on this type of gain under Part III of the Act will apply, whereas by making this Amendment the Chancellor is only allowing losses under Case VII of Schedule D. As the Bill is worded, an art dealer could take advantage of losses sustained prior to the Bill. I would agree with the Amendment, but it is wrong to describe it as a clarifying Amendment.

The right hon. Gentleman also owes us an explanation on Amendment No. 567. It is rather remarkable to call that a clarifying Amendment, because it completely deletes a subsection. That seems a new way of clarifying a Bill. A very good way of clarifying the Bill might be to delete the whole of this part, but, as the Government are intent on using this method, some explanation is required of why the Government inserted the subsection and then decided that they should delete it.

There is some mystery about the subsection because, as far as I can see, it is the only subsection which is not referred to in the White Paper. All other subsections have a little note about them in the White Paper, but when the Chancellor drew up the White Paper and he came to the famous subsection (4) he decided that it was not worth commenting on. If it was not worth commenting on, and if the Government discovered this at the stage of printing the White Paper, which was published at the same time as the Bill, it is remarkable that the Bill at first contained the subsection. We on this side immediately rushed to paragraph 3 of the Sixth Schedule to see what grave implications the subsection had. I spent many hours trying to fathom what it meant and came to the conclusion, to which the Chancellor has presumably now come, that it is complete nonsense. Therefore, I ask the Minister without Portfolio to explain why the subsection was ever in the Bill and to admit that these Amendments are not just clarifying Amendments.

Sir Eric Fletcher

I should have thought that it was obvious from what the hon. Gentleman has said that the deletion of subsection (4) clarifies this part of the Bill. In deference to the Committee, perhaps I should elaborate a little more. Subsection (2,a), together with subsections (3) and (4), were intended to ensure that all the gain arising to a company from the disposal after Budget day of an asset acquired before Budget day would be chargeable to Capital Gains Tax, if the acquisition and the disposal took place within the old short-term tax time limits.

We came to the conclusion that it was doubtful whether the subsections as they stood successfully secured that result. Subsection (4) reads: Subsection (2)(a) above, shall not affect paragraph 3 of Schedule 6 to this Act. We came to the conclusion that the subsecution had an element of obscurity about it, that it was not necessary to give effect to the intentions, which are agreed intentions, of this part of the Clause, and therefore that the Bill would be much clearer if it were deleted.

Mr. Peter Walker

I must confess that the Minister without Portfolio has almost convinced me that subsection (4) is necessary. I suspect that we will leave a serious gap in the Bill and allow all sorts of evasion to take place if we allow it to go. I take note of the Minister without Portfolio's answer. I suggest that we accept the Amendments.

Amendment agreed to.

Further Amendments made: In page 100, line 16, leave out subsection (4).

In line 18, leave out from "Any" to "in" in line 21, and insert: losses which are allowable against chargeable gains under subsection (1) above or would be so allowable but for the company being within the charge to corporation tax from the beginning of the year 1965–66,".

In line 45, leave out from "tax" to end of line 1 on page 101.

And in page 101, line 2, leave out from "shall" to second "to" in line 3 and insert: extend to all the provisions of Schedule 12 to this Act, including those relating to the recovery of tax, and".—[Sir E. Fletcher.]

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

Mr. Peter Walker

Having granted the Government five quick Amendments, there is one aspect of the Clause which should be discussed. The Clause is basically divided into two parts, one dealing with the fact of seeing that the Capital Gains Tax on certain companies shall be charged although perhaps those companies may not come under the Corporation Tax provisions. This, I presume, is to capture companies which, for example, cease trading at the end of the year, which we fully understand.

On that part of the Clause we on this side of the Committee have constantly complained of the manner in which companies are going to be taxed thus causing double taxation to the individual. We have pointed out the unfairness of this proposal on investment trusts and unit trusts. We heard the other day from the Chief Secretary that as a result of these provisions insurance companies were to be taxed to the extent of £23 million a year out of their funds. We have given many examples, which I will not repeat, of why we are opposed to double taxation when a capital gain occurs within a company. Therefore, we are opposed to this Clause, as we have been opposed to previous Clauses which have brought about this injustice where the share holder is taxed at 54 per cent. rather than at 30 per cent.

On the remainder of the Clause there is a very important point of principle which I would ask the Minister to explain. Basically this Clause is doing away with the short-term Capital Gains Tax of the company and it is substituting for it the permanent long-term Capital Gains Tax that the Government consider necessary. This brings about a very interesting and wide gap between the treatment of the individual as opposed to the treatment of the company. Previously the individual was taxed for short-term Capital Gains Tax at the rate of Income Tax and Surtax, and the company was taxed at the rate of Income Tax and Profits Tax. Therefore, we have a situation in which the Government have decided that so far as the company is concerned they will substitute for the 56¼ per cent. rate of tax on short-term capital gains the much lower rate of 35 per cent. or 40 per cent. depending on the rate of Corporation Tax.

So the company has been treated to a considerable reduction in the rate of tax as far as short-term capital gains are concerned. But the individual, instead of being charged a reduced rate of tax for short-term capital gains, has had the period in which he can suffer from the higher rates of tax increased. We therefore have the position in which the individual, when the capital gain takes place in the first 12 months, will be taxed at the rate of Income Tax and Surtax whereas the company will be taxed at the rate of Corporation Tax. This means that the majority of people who decide to engage in any form of transaction which is liable to result in a short-term capital gain are likely to do it by forming a company, thereby paying the 35 per cent. rate of tax, rather than do it as an individual which would render them liable to pay Income Tax and Surtax.

Mr. Lubbock

In fact, they will not pay 35 per cent. They will pay 56 per cent.

Mr. Walker

I agree, but as far as the Surtax payer is concerned the original rate will be a better proposition. It will pay the Surtax payer on the higher rate to form a company to carry out the transaction and pay the total of 54 per cent. instead of paying the higher tax which he would pay otherwise.

There must be some explanation why the Government have decided that for companies it is right to have the one level of Capital Gains Tax of 35 per cent. or 40 per cent., whichever it may be, but, for the individual, to continue to have a very high and, for some people, penal rate of taxation for the first 12 months. This is a remarkable difference in treatment for the individual and for the company, and this difference requires some explanation.

11.45 p.m.

Sir Eric Fletcher

The hon. Member for Worcester (Mr. Peter Walker) made two points. First, he pointed out that to some extent the Opposition wish to repeat on this Clause the objections which they previously raised to companies being liable to Corporation Tax on capital gains. In so far as he made that argument he was doing no more than repeating arguments addressed to the Committee on earlier Clauses and therefore I do not think that I need deal with them. Over and over again we have indicated why we think that all the gains, whether profits in the old sense or capital gains accruing to a company, should be chargeable for Corporation Tax, and it would be tedious to repeat the arguments put forward by my hon. and right hon. Friends in that respect.

Secondly, a point of some detail which I was asked to explain was why the Government have adopted this method of dealing with the interim charge of tax on capital gains of companies and to explain why there appears superficially to be a distinction between the treatment of individuals and the treatment of companies in respect of the change from short-term capital gains to long-term capital gains. In part the answer to the hon. Member is that this is inherent in the complete separation of Income Tax and Surtax for individuals and Corporation Tax for companies.

In so far as the short-term capital gain is being abolished, it is not entirely correct to say, as the hon. Member said, that the period of operation of the short-term Capital Gains Tax is being extended. In the case of moveables it is being extended from six months to 12 months, but in the case of land it is being reduced from three years to one year. Therefore the apparent contradiction to which the hon. Member referred is in part a reflection of the fact that the whole concept of short-term capital gains with differential time limits according to whether land or securities is involved is being replaced by one with a single operative time limit.

It is far-fetched for the hon. Member to think that some individuals will be tempted to form companies to get the apparent benefit of being able to deal with short-term capital gains. We do not think that the provisions in the Clause will have those undesirable results and although I suppose there will inevitably be some anomaly or difficulty somewhere in translating short-term capital gains with two differential terminal periods into long-term capital gains and making the appropriate transitional provisions, we think that this is by far the best and fairest provision that could be devised.

Sir D. Glover

I understand the Minister without Portfolio to say that my hon. Friend the Member for Worcester (Mr. Peter Walker) was wrong in saying that the Government were extending short-term Capital Gains Tax from six months to 12 months. The hon. Gentleman said that it was not true because in the case of land the period was being reduced from three years to 12 months. Is not this exactly the situation to which my hon. Friend was drawing attention in his interjection? If the period in respect of land is reduced to 12 months, would not that be exactly the situation in which somebody entering into purchase would form a company, because by doing so he would avoid the excess which otherwise he would have to pay in Income Tax and Surtax? The very fact that the period for land is being reduced from three years to one year shows how inadequately, as usual, the Government have thought out their proposal. The Government must look at this again. At present, the Clause is nonsense.

Mr. Peter Walker

On the first point which the Minister made, although he is quite right to say that we have had the arguments about double taxation before, I must impress upon him how important we regard these matters. Through our proceedings, it has been shown that unit trusts, investment trusts and settlements—the hon. Member for Orpington (Mr. Lubbock) dealt with them—all are caught by double taxation as a result of including companies in this way. Therefore, from that point of view alone, we are dissatisfied with the Clause.

As regards the short-term differential, the Minister is underestimating the importance of this question. The Government have decided that for companies the rate of short-term Capital Gains Tax is to be reduced from 56¼ per cent. to 35 per cent. For the individual, they have decided that for the majority of transactions it shall stay at the rate of Income Tax and Surtax for a far longer period. The Minister said that he did not really think that people would bother to form a company for the purpose of these transactions. His advisers are bound to advise anyone who is a Surtax payer above the level of 56¼ per cent. to form a company for that purpose. Therefore, by the way the Clause has been drafted, the Government are putting a maximum level of short-term Capital Gains Tax on anyone who is well advised of 56¼ per cent., which, presumably, is what they do not want to do because they would like to catch such a person for Income Tax and Surtax.

I am sure that, on reflection, the Government will find that they will want to introduce some Amendments on Report. They have moved five Amendments to this Clause already, whereas the average has been only three Government Amendments to each Clause so far.

However, in spite of five Amendments to it, this still remains a thoroughly bad Clause, and I advise my hon. and right hon. Friends to divide against it.

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

The Committee divided: Ayes 152, Noes 146.

Division No. 193.] AYES [11.52 p.m.
Abse, Leo Hale, Leslie Orme, Stanley
Allaun, Frank (Salford, E.) Hamilton, James (Bothwell) Oswald, Thomas
Alldritt, Walter Hamilton, William (West Fife) Padley, Walter
Allen, Scholefield (Crewe) Hannan, William Pearson, Arthur (Pontypridd)
Armstrong, Ernest Harper, Joseph Peart, Rt. Hn. Fred
Bacon, Miss Alice Harrison, Walter (Wakefield) Pentland, Norman
Bagier, Gordon A. T. Hart, Mrs. Judith Perry, Ernest G.
Barnett, Joel Hattersley, Roy Popplewell, Ernest
Beaney, Alan Herbison, Rt. Hn. Margaret Price, J. T. (Westhoughton)
Benn, Rt. Hn. Anthony Wedgwood Hobden, Dennis (Brighton, K'town.) Probert, Arthur
Bennett, J. (Glasgow, Bridgeton) Holman, Percy Rankin, John
Bishop, E. S. Houghton, Rt. Hn. Douglas Rees, Merlyn
Blackburn, F. Howie, W. Rhodes, Geoffrey
Blenkinsop, Arthur Hoy, James Richard, Ivor
Boardman, H. Hughes, Emrys (S. Ayrshire) Roberts, Albert (Normanton)
Bowden, Rt. Hn. H. W. (Leics, S.W.) Hunter, Adam (Dunfermline) Robertson, John (Paisley)
Boyden, James Irving, Sydney (Dartford) Rodgers, William (Stockton)
Braddock, Mrs. E. M. Jackson, Colin Rogers, George (Kensington, N.)
Bray, Dr. Jeremy Jay, Rt. Hn. Douglas Short, Rt. Hn. E. (N'c'tle-on-Tyne, C.)
Buchan, Norman (Renfrewshire, W.) Jeger, George (Goole) Silkin, John (Deptford)
Buchanan, Richard Jones, Dan (Burnley) Slater, Mrs. Harriet (Stoke, N.)
Callaghan, Rt. Hn. James Kenyon, Clifford Slater, Joseph (Sedgefield)
Carmichael, Neil Lawson, George Small, William
Coleman, Donald Lee, Rt. Hn. Frederick (Newton) Smith, Ellis (Stoke, S.)
Conlan, Bernard Lever, L. M. (Ardwick) Soskice, Rt. Hn. Sir Frank
Corbet, Mrs. Freda Lewis, Ron (Carlisle) Steele, Thomas (Dunbartonshire, W.)
Craddock, George (Bradford, S.) Lomas, Kenneth Stewart, Rt. Hn. Michael
Cullen, Mrs. Alice McBride, Neil Stones, William
Dalyell, Tam McCann, J. Summerskill, Hn. Dr. Shirley
Davies, G. Elfed (Rhondda, E.) MacDermot, Niall Swingler, Stephen
Davies, S. O. (Merthyr) McGuire, Michael Taylor, Bernard (Mansfield)
Diamond, Rt. Hn. John McInnes, James Thomas, Iorwerth (Rhondda, W.>
Doig, Peter McKay, Mrs. Margaret Thomson, George (Dundee, E.)
Donnelly, Desmond Mackenzie, Gregor (Rutherglen) Thornton, Ernest
Duffy, Dr. A. E. P. Mackie, John (Enfield, E.) Tinn, James
Dunn, James A. MacMillan, Malcolm Urwin, T. W.
Edwards, Rt. Hn. Ness (Caerphilly) Mahon, Simon (Bootle) Wainwright, Edwin
Ensor, David Manuel, Archie Walden, Brian (All Saints)
Fernyhough, E. Mapp, Charles Walker, Harold (Doncaster)
Fletcher, Sir Eric (Islington, E.) Marsh, Richard Wallace, George
Fletcher, Ted (Darlington) Mason, Roy White, Mrs. Eirene
Floud, Bernard Maxwell, Robert Whitlock, William
Foley, Maurice Mendelson, J. J. Wigg, Rt. Hn. George
Fraser, Rt. Hn. Tom (Hamilton) Millan, Bruce Willey, Rt. Hn. Frederick
Galpern, Sir Myer Miller, Dr. M. S. Williams, Clifford (Abertillery)
Garrett, W. E. Milne, Edward (Blyth) Willis, George (Edinburgh, E.)
George, Lady Megan Lloyd Morris, John (Aberavon) Winterbottom, R. E.
Ginsburg, David Murray, Albert Yates, Victor (Ladywood)
Gourlay, Harry Neal, Harold
Gregory, Arnold Oakes, Gordon TELLERS FOR THE NOES:
Griffiths, David (Rother Valley) Ogden, Eric Mr. Ifor Davies and
Griffiths, Rt. Hn. James (Llanelly) O'Malley, Brian Mr. Alan Fitch.
NOES
Agnew, Commander Sir Peter Bessell, Peter Bruce-Gardyne, J.
Alison, Michael (Barkston Ash) Birch, Rt. Hn. Nigel Bullus, Sir Eric
Allason, James (Hemel Hempstead) Black, Sir Cyril Chataway, Christopher
Anstruther-Gray, Rt. Hn. Sir W. Bossom, Hn. Clive Chichester-Clark, R.
Astor, John Bowen, Roderic (Cardigan) Clark, William (Nottingham, S.)
Awdry, Daniel Box, Donald Cole, Norman
Barber, Rt. Hn. Anthony Boyd-Carpenter, Rt. Hn. J. Cooke, Robert
Barlow, Sir John Boyle, Rt. Hn. Sir Edward Cooper-Key, Sir Neill
Batsford, Brian Brewis, John Crosthwaite-Eyre, Col. Sir Oliver
Bennett, Sir Frederic (Torquay) Brinton, Sir Tatton Curran, Charles
Berry, Hn. Anthony Brown, Sir Edward (Bath) Dalkeith, Earl of
Davies, Dr. Wyndham (Perry Barr) Johnson Smith, G. (East Grinstead) Pickthorn, Rt. Hn. Sir Kenneth
d'Avigdor-Goldsmid, Sir Henry Johnston, Russell (Inverness) Pike, Miss Mervyn
Dean, Paul Kaberry, Sir Donald Pitt, Dame Edith
Digby, Simon Wingfield Kerr, Sir Hamilton (Cambridge) Powell, Rt. Hn. J. Enoch
Dodds-Parker, Douglas Kershaw, Anthony Prior, J. M. L.
Emery, Peter King, Evelyn (Dorset, S.) Pym, Francis
Errington, Sir Eric Kirk, Peter Rawlinson, Rt. Hn. Sir Peter
Eyre, Reginald Legge-Bourke, Sir Harry Renton, Rt. Hn. Sir David
Farr, John Litchfield, Capt. John Ridley, Hn. Nicholas
Fisher, Nigel Lloyd, Ian (P'tsm'th, Langstone) Roberts, Sir Peter (Heeley)
Fletcher-Cooke, Sir John (S'pton) Longden, Gilbert Roots, William
Foster, Sir John Lubbock, Eric Scott-Hopkins, James
Fraser, Ian (Plymouth, Sutton) MacArthur, Ian Stanley, Hn. Richard
Gammans, Lady Mackenzie, Alasdair (Ross & Crom'ty) Steel, David (Roxburgh)
Gibson-Watt, David Mackie, George Y. (C'ness & S'land) Stodart, Anthony
Giles, Rear-Admiral Morgan McLaren, Martin Stoddart-Scott, Col. Sir Malcolm
Glover, Sir Douglas McNair-Wilson, Patrick Studholme, Sir Henry
Gower, Raymond Maitland, Sir John Talbot, John E.
Grieve, Percy Mathew, Robert Taylor, Edward M. (G'gow, Cathcart)
Griffiths, Peter (Smethwick) Maude, Angus Taylor, Frank (Moss Side)
Grimond, Rt. Hn. J. Maudling, Rt. Hn. Reginald Teeling, Sir William
Gurden, Harold Maxwell-Hyslop, R. J. Temple, John M.
Hall-Davis, A. G. F. Maydon, Lt.-Cmdr. S. L. C. Thomas, Rt. Hn. Peter (Conway)
Harris, Frederic (Croydon, N.W.) Meyer, Sir Anthony Turton, Rt. Hn. R. H.
Harvey, John (Walthamstow, E.) Mills, Peter (Torrington) van Straubenzee, W. R.
Harvie Anderson, Miss Mills, Stratton (Belfast, N.) Walder, David (High Peak)
Hawkins, Paul Mitchell, David Walker, Peter (Worcester)
Heald, Rt. Hn. Sir Lionel Monro, Hector Walker-Smith, Rt. Hn. Sir Derek
Heath, Rt. Hn. Edward More, Jasper Wall, Patrick
Higgins, Terence L. Morrison, Charles (Devizes) Ward, Dame Irene
Hill, J. E. B. (S. Norfolk) Munro-Lucas-Tooth, Sir Hugh Webster, David
Hobson, Rt. Hn. Sir John Murton, Oscar Whitelaw, William
Hooson, H. E. Noble, Rt. Hn. Michael Wilson, Geoffrey (Truro)
Hornsby-Smith, Rt. Hn. Dame P. Osborn, John (Hallam) Yates, William (The Wrekin)
Howard, Hn. G. R. (St. Ives) Page, R. Graham (Crosby) Younger, Hn. George
Hunt, John (Bromley) Pearson, Sir Frank (Clitheroe)
Hutchison, Michael Clark Peel, John TELLERS FOR THE NOES:
Jenkin, Patrick (Woodford) Percival, Ian Mr. R. W. Elliott and
Jennings, J. C. Peyton, John Mr. Dudley Smith.
Mr. Edward Heath (Bexley)

I beg to move, That the Chairman do report Progress and ask leave to sit again. I do so in order to ask the Chancellor of the Exchequer what his intentions are. It is now midnight, we have been debating for 8½ hours and all those who have listened to the debates will agree that they have all been serious. They have at the same time been extremely detailed, because we are dealing with a complex part of the Bill. We are now faced with Clause 78, to which the Government have put down a considerable number of Amendments which have recast the Bill. In addition, the Chairman of Ways and Means has selected, as I calculate, 11 Opposition Amendments for debate on Clause 78, many of which will be major debates.

On Clause 79, when we start considering the transitional provisions for Corporation Tax and those companies trading overseas, the Government are again recasting by a considerable number of major Amendments. I must therefore point out that if the right hon. Gentleman wishes to continue the discussion of the Bill at this stage he is embarking on an all-night Sitting again.

As tomorrow there are, in the Palace of Westminster, to be celebrations to which I understand all hon. Members attach considerable importance, I must make it plain to the right hon. Gentleman that he and the Government are themselves entirely responsible for embarking on an all-night Sitting.

The Parliamentary Secretary to the Ministry of Labour (Mr. Richard Marsh) indicated dissent.

Mr. Heath

I hope that the Parliamentary Secretary to the Ministry of Labour is not suggesting that the Government are irresponsible. The Government are entirely responsible for embarking on an all-night Sitting of the Committee prior to a day on which these important events are to take place.

The Chancellor of the Exchequer (Mr. James Callaghan)

I think that it is very reasonable of the right hon. Gentleman the Member for Bexley (Mr. Heath) to ask what the Government's intentions are in this matter and I want to be as frank as I can. It is true that we have had a number of detailed debates today and it is not for me to comment on the length of them, except to say that one Clause took us six hours to dispose of—I am not drawing conclusions; I am merely stating the facts—although there had been a number of earlier discussions on very similar points. Since then we have moved very fast.

During the last two hours, with the help of the whole Committee and with hon. Members keeping their speeches reasonably short—I hope that no one will mind my saying that—we have secured five Clauses. If it had been possible to make quicker progress in debating the Clause which took six hours, I would certainly have hoped to have moved to report Progress at about this time. However, we spent rather a long time on one Clause—I do not complain about it, but merely state that it was so. We want a full attendance in Westminster Hall tomorrow. I shall certainly be there and I hope that all my hon. and right hon. Friends and that everybody else will be there for the celebrations, but we must make some further progress tonight. There is important work for us to do.

We need not be overwhelmed by the number of debates which can arise, because many of them will be on concessions. I know that that is a word which I must not use, but they represent Amendments by the Government to meet representations which have been made by industry and commerce and right hon. and hon. Gentlemen opposite. It would not be right to deduce from the number of Amendments to be discussed that they will necessarily take the time which might be assumed. If there are Amendments which both concede a good deal of money and at the same time meet the legitimate points which have been put to us, there is not the same necessity, I hope, to debate them at any great length. I merely say that I hope to conclude at an early hour. I hope that we shall not go on too long, but that we should like to make a little more progress and see how far we can get tonight.

Mr. Heath

The Chancellor of the Exchequer has been far from explicit about what he hoped to do. We can deduce only that he has not reached firm decisions about what point of the Bill he would like to reach. He said that he would deal only with facts. He said that we had spent six hours on Clause 72, which is a very important Clause dealing with the pith and substance of close com- panies and for a large part of the debate it was one for one from each side of the Committee. The most violent row of the debate, in so far as there has been a row, took place between the hon. Member for Manchester, Cheetham (Mr. Harold Lever), who now seems to have been banished from the Chamber—

Mr. Harold Lever indicated dissent.

Mr. Heath

—and his right hon. Friend the Chief Secretary. I quote the hon. Gentleman as saying that a large part of Clause 72 was fallacious in logic and being perpetrated by sheer obstinacy. Nothing like that has been said from this side of the Committee in the whole of the day's discussion. That shows that the Clause was a very important matter to both sides of the Committee.

We will proceed with Clause 78 and I make it clear and public that the responsibility rests firmly on the shoulders of the Government. What we have found it very difficult to bring home to the Government is that discussion of the complicated details of a Bill of this kind takes far more time than they have ever allowed, even when Ministers are only moving Government Amendments and explaining what they mean. It was quite evident to the Committee that Clause 72 was of considerable importance. Now we have to continue the process.

The Committee appreciates the Amendments which the Chancellor has brought forward to meet the various representations which have been made to him, but that does not alter the fact that many other representations have been made to him which he has not yet found himself able to meet. It is only right that hon. Members should put forward Amendments dealing with those matters and argue the case in a serious and reasoned manner.

So we shall continue what we have done for 13 days on this Bill and argue these important matters seriously and in detail, and I therefore beg to ask leave to withdraw the Motion.

Motion, by leave, withdrawn.