§ (1) Any expense not exceeding £40 which is incurred by an individual in respect of professional assistance in or incidental to preparing his return of income and statement of capital gains and claim for allowances in any year of assessment shall be deducted from or set off against his income for that year.
(2) A deduction as provided in subsection (1) shall also be allowed in respect of professional assistance in complying with notices under the Income Tax Acts, and any enactment relating to the Capital Gains Tax:
Provided that, if such notice in respect of information relating to the liability of some person other than the person on whom the notice is served, the deduction shall operate in respect of the income for the next follow-
ing year of assessment of the person on whom the notice is served.
§ (3) For the purposes of this section—
- (a) 'professional assistance' means assistance provided by a solicitor, a member of an incorporated society of accountants, a bank, a stockbroker or a member of such professional body as the Commissioners of Inland Revenue shall certify as qualifying under this section; and
- (b) 'individual' shall include the trustees and personal representatives of an individual.
§ (4) This section shall not apply in computing the total income of any individual for the purposes of surtax.—[Mr. John Hall.]
§ Brought up, and read the First time.
§ Mr. John Hall (Wycombe)
I beg to move, That the Clause be read a Second time.
1791 I hope that I am right in thinking that the countenance of the Chief Secretary, who is to reply, means that he has spent a happy weekend basking in the sun and is, therefore, receptive. Although few proposals to reduce taxation have merit in the eyes of the Treasury Bench, this one has virtues which should appeal. It is modest, it does not apply in computing income for Surtax—that should appeal to hon. Members opposite—it insists that assistance for which a charge may be made must be provided by recognised professional advisers. Documentary evidence will have to be produced, of course, before the allowances are granted.
The present law does not allow professional assistance in computing Income Tax returns either to the individual or to the trading concern, but things are different in practice. Whereas the full rigours of the law apply to the individual, for expediency or administrative convenience the Inland Revenue does not apply it to those who return their tax forms under Schedule D or Schedule A.
The Royal Commission on the Taxation of Profits and Income put this quite simply. I am quoting only the relevant part and am not being selective. In paragraph 928, it said:… in practice the costs of preparing tax returns are allowed in an assessment of business profits under Schedule D: not directly as tax returns, but indirectly, because the ordinary costs of getting out the accounts are regarded as chargeable in a computation of business profits and these costs are not dissected in order to arrive at the separate cost of converting these accounts into tax returns. Again, when income is computed under Schedule A, the expense of preparing a maintenance claim is allowed as part of the claim itself…That was in a Report published in 1955. Then the arguments against this allowance, which appear on the face of it to constitute an obvious injustice, were said to be justified by the Royal Commission in recommending that there should be no change in the practice.
The Report went on to say:Thus there is no definite principle, but there is a lack of consistency in practice … It seemed to us probable that, even without conscious design, the existing allowances fell where they were most needed, in the sense that the business account and the maintenance 1792 claim are the most onerous to prepare privately and the most likely to require professional assistance in their preparation; and the arguments against a general allowance appeared, on balance, to justify the present position.The argument against the general allowance appeared to the Royal Commission onlyon balance to justify the present position".This was before a Socialist Chancellor of the Exchequer created chaos and confusion in a fiscal system which increased the risk of coronaries and duodenal ulcers in the accountancy and legal professions. It would seem that it will not be long before they join Members of Parliament and other high-risk professions in asking for danger money.
§ Mr. J. T. Price (Westhoughton)
Whatever the merits of the argument might be, the hon. Member has quoted a Report of 1955. Many of us are familiar with the argument, but he and his political friends were in full control of the Treasury in 1955. If they thought there was injustice then, why did they not take the necessary action? Why does the hon. Member shed crocodile tears over this in 1967?
§ Mr. Hall
The hon. Member should have waited until I had developed my argument. Much has happened during the 12 years since that Report was issued. If that Commission were examining the position against the background of our present fiscal situation, I am sure that it would agree that the balance should be tilted the other way, in favour of granting a general allowance.
For the individual taxpayer, the main difficulty arises over capital gains. Many people find the whole of the tax return incomprehensible. It is a common experience of men and women, particularly women, who are outstanding in their particular professions. They suffer a form of mental paralysis when they are faced with the necessity of completing the return. Many taxpayers are quite unaware of their full entitlement to allowances and reliefs. There were Members of Parliament who were unaware of their rights in this respect, but we have been deeply indebted to my hon. Friend the Member for Worcestershire, South (Sir G. Nabarro) for drawing our attention to the many allowances which we are entitled to claim.
1793 The Income Taxpayers' Association pointed out in a recent Report thatMany people find these forms quite incomprehensible and have to pay for assistance to complete them correctly.I understand that the Association, at its annual general meeting yesterday, considered a motion which demanded an allowance of £40, rather on the lines of this new Clause.
In the computation of capital gains, the taxpayer finds himself at the greatest loss if he is not properly professionally advised. I am sure that the Chief Secretary, remembering his previous incarnation, would not disagree about that. An instance which immediately springs to mind is one to which I drew attention in Amendment No. 183, earlier in our proceedings, relating to the two alternative methods of calculating capital gains made on realisation of assets acquired before 6th April, 1965, and which asked for certain considerations to be taken into account. That Amendment was rejected. It is, therefore, all the more essential that any taxpayer faced with the necessity of choosing one of the alternatives should be fully, and properly professionally advised.
I also drew attention last year—not in moving the Second Reading of a Clause of this kind, but in dealing with capital gains in general—to the kind of case which can cause a great deal of trouble and difficulty when a computation has to be worked out. As reported in column 808 of the OFFICIAL REPORT for 22nd June, 1966, I quoted an example of the sort of transaction which might be quite normal involving about 14 transactions of acquisition or disposal of shares.
The example I quoted had been used by a lecturer in attempting to explain to a number of professional people the intricacies of the tax. I pointed out that it took him an hour and 20 minutes, with the use of a blackboard, to explain one case in the computation and the actual gain was £317 over a period of 10 years. There are many cases of this kind which create great difficulty for the individual taxpayer who tries to do this work without the professional advice of an accountant or similar adviser.
In calculating the cost of acquisition or disposal for the purpose of capital 1794 gains, some expenses are allowed. Fees paid to surveyors, valuers, auctioneers and even accountants and legal advisers wholly and exclusively incurred for the acquisition or disposal of the assets are allowed, as are the fees paid to the accountants which relate to the valuation or opportionment of disposal of securities, but they are not allowed for fees for the normal calculation of gains or losses. This means that whether or not the total fee charged by an accountant is allowable for tax depends on the flexibility with which the accountant interprets the provision. No doubt in many cases the part allowable is absorbed by the part which is not legally allowable.
I do not wish to take up the time of the Committee in developing this at great length, for I believe that the problem is well known. Nor do I insist that the wording of the Clause. We are debating the principle of the Clause. If it had to be amended in any way which gave the same result I would be happy to accept such amendment. The present position has always been unsatisfactory. It has now become unjust. It favours one class of taxpayer against another. It invites evasion and is a source of continuing irritation. If the arguments were finely balanced 12 years ago—and the Royal Commission said that it was only on balance that it recommended against giving a general allowance—now, with the changes which have taken place in that period, the hand of justice should tilt the scales in favour of the taxpayer.
I feel certain that in recommending this Clause to the Committee I shall have the professional sympathy of the Chief Secretary, although whether I shall have his sympathy in his capacity as a Treasury Minister I am not absolutely certain. I can only pray for the best.
§ Mr. Barnett
The hon. Member for Wycombe (Mr. John Hall) expressed concern for accountants. I must declare my interest as an accountant, as the senior partner in a practice. Of course, I have the dual capacity which the hon. Gentleman was worried about in that I am also a Member of Parliament, so I suppose that I have something to worry about in that sense. As last year, I am, broadly, in favour of the idea behind the new Clause, although I am worried about the practical effects, knowing as I do how many returns 1795 are piled up and awaiting completion in my office at the moment.
I support the idea on the ground of equity between those paying tax on P.A.Y.E. and those paying tax under Schedule D. Last year, my right hon. Friend the Chief Secretary said that the hon. Member for Oswestry (Mr. Biffen) was nearly on a good point on the ground of equity. I suggest that my right hon. Friend was nearly on a good point, but not quite, in his reply. He gave three answers to the argument of the hon. Member for Oswestry.
Replying to the argument that accountants' fees for the preparation of accounts and tax computations should be allowable, his three answers were that it was not the case in law, that it was not universally the case in practice, and, where it was the case in practice, it was only because of the impossibility of segregating out. I should like to deal with those three answers and with my right hon. Friend's reasons for not being able to accept the proposal on the ground of equity.
It is true that making no distinction is not universal, but that is stretching the argument, because there is no distinction in 99 per cent. of the cases and it is only in a very minute number—for example, when an accountant is dealing with back duty there is clearly an expense in relation to the back duty, where there is clearly a tax problem—when it is easy to say that an aspect of the charge is not related to accountancy matters and that it is possible to say that there is a distinction. But in almost all other cases the whole of the charge is allowed.
On the question of law, last year I felt that to some extent my right hon. Friend was annunciating a new doctrine. The accountant's charge is allowed under Section 137 of the Income Tax Act, 1952, because with a Schedule D expense it is wholly and exclusively incurred for the purposes of trade. On the other hand, last year my right hon. Friend gave the distinction as being, on the one hand, computing business accounts and, on the other, computing for tax purposes.
This seems to be a rather different situation, because it would be difficult to argue that many thousands of small payers would go to the trouble of having accounts prepared at all were it not for tax purposes. I hasten to add that I am not sug- 1796 gesting that the charge should not be allowed, but we are here discussing equity and there can be little doubt that the only reason why hundreds of thousands of people in small businesses have accounts prepared is for tax purposes. It is, therefore, difficult to argue that the whole of the charge should be allowed for computing business accounts, because that does not seem to comply with Section 137 of the Income Tax Act.
On the other hand, it could be argued, at least to some extent and probably with greater force, that the preparation of Income Tax returns and the calculation of tax was essential to an individual in the actual earning of his income. It could be argued that a man would or would not work overtime, or would work normally, if he knew the extent of his liability. It can be argued that it is at least as equitable to allow the expense to that sort of individual as to the Schedule D taxpayer who pays the charge only for tax purposes.
The hon. Member for Wycombe referred to capital gains. I want to quote from an article mentioned earlier today in another context, the article which appeared in the Sunday Times of last Sunday, and in which the ignorance of the hon. Member for Worcestershire, South (Sir G. Nabarro) was exposed. Referring to the alternative method of calculating capital gains, the writer said:It also suggests that every investor should take a close look at his individual tax position before deciding to cash in on a hefty capital gain.If a taxpayer is entitled to know what his tax position is—and that is relevant to deciding the gain—that is an expense directly attributable to the earning of the income and to what extent, even if the word "necessarily" is excluded, as it is for Schedule D purposes, it is an indication that there is a considerable amount of equity in allowing the charge.
The other argument of my right hon. Friend last year was that it was impossible to segregate out the private element. He must know that, in practice and generally, segregating out an expense and deciding which is business and which is not business is generally, if not always, a compromise, a proportion, because it is impossible to segregate out.
This applies to motor car expenses, for example. One argues with the inspector 1797 about how many hundreds of miles are run for private purposes between the home and the business and how many for business purposes, but in the end there is a compromise between the accountant and the inspector as to whether it should be one-seventh, or one-tenth, or one- twelfth, or whatever proportion can be agreed as that which should be segregated out. This is because it is recognised that it is not possible to say with certainty what part should be segregated out.
Indeed, hon. Members are now having similar problems with the Revenue, which suggests that part of the expense of having a flat in London, for example, should be segregated out as being for private benefit. In that instance it is a little difficult to be precise about what the proportion should be. I hope that the Revenue will agree that no part should be segregated out.
Clearly, my right hon. Friend's argument about segregating out does not hold water. In every case where there is an item in a profit and loss account about which there is some dispute, there has to be a compromise, because it is not possible to be precise about the amount which ought to be segregated out, and it seems to me that some element of this expense should be allowable.
It may be equitable to concede 50 per cent. of the charge of an accountant for doing an Income Tax return and to allow that as a general concession if my right hon. Friend is not prepared to go the whole way. This would help to meet the case on equity grounds, which my right hon. Friend last year conceded to be the point nearest to being accurate and which I have shown that he did not answer.
On the ground of equity it seems wrong that many millions of taxpayers paying tax under P.A.Y.E. should have this inhibiting word "necessarily" included in the rule, which means that they are not allowed to charge for accountants' fees—not, I hope, that they are likely to come rushing to accountants if this concession is made, but at least it would bring home to them the advantages which might accrue.
For example, ordinary taxpayers could benefit from joining in tax avoidance. Many thousands who are claiming depen- 1798 dent relative relief do not realise that they would be very much better off if they dropped their claim for dependent relative relief and paid their dependent relatives under covenant. This is only one small example, but there are many others where, at least on grounds of equity, the pay-as-you-earn taxpayer is entitled to the right sort of advice so that he does not pay more tax than he should under the law as it stands.
On the ground of equity, therefore, I hope that my right hon. Friend will be inclined if not to accept the Clause at least to go some way towards making a concession.
§ Mr. Daniel Awdry (Chippenham)
I was hoping that the hon. Member for Heywood and Royton (Mr. Barnett) would give us a few more interesting ways by which we could improve our tax position. I am sorry that he stopped when he did.
I feel very strongly about the Clause. This debate is, in effect, a rehearing of the debate last year, and I assume that all of us who are taking an interest today have read and studied the thoroughly unsympathetic reply which the Chief Secretary gave on that occasion. The right hon. Gentleman will not need reminding, but I shall remind him nevertheless, of what he said:The short answer is that on his three grounds, the hon. Gentleman "—this was my hon. Friend the Member for Oswestry (Mr. Biffen)—does not make his case. But the overwhelming point is the one to which the Royal Commission on the Taxation of Profits and Income drew attention, and that is the real argument of principle to which, in his speech, the hon. Gentleman did not turn his mind ".—[OFFICIAL REPORT, 4th July, 1966; Vol. 731, c. 144–5.]That argument has been completely demolished by my hon. Friend the Member for Wycombe (Mr. John Hall) today.
The Report of the Royal Commission in paragraph 929 is quite clear:Thus there is no definite principle, but there is a lack of consistency in practice",and it goes on in these important words, which have been quoted already:It seemed to us probable that, even without conscious design, the existing allowances fell where they were most needed, in the sense that the business account and the maintenance claim are the most onerous to prepare privately and the most likely to require professional assistance in their preparation".1799 I ask the Committee to note the difference here. The Chief Secretary talked about the "real argument of principle", calling in aid the Royal Commission, which said that "there is no definite principle". Of course, there is no principle. We all know that. It is a matter of judgment, and I hope that, in his reply today, the right hon. Gentleman will talk no more about the question of principle.
The Royal Commission said that allowances should be given where claims are onerous and likely to require professional assistance. We all know what the truth of the matter is. I am a solicitor, not an accountant, but I can speak from personal experience, as well. Many people find it impossibly difficult to fill in their tax forms today. A great number go to accountants, and on difficult claims they are well advised to do so, but on fairly simple cases, where there is not much tax law, perhaps, a solicitor can give the answer.
I know from experience as a country solicitor that many of these people have very small incomes. I should not have spoken in the debate today had not a widow come to see me last week about her Income Tax return. Her income was about £750 a year—that is all—but her husband had invested his money in many different stocks and shares, all in separate small parcels. That was rather unwise, perhaps. He might have done better to go to a building society, but that is what he did, wanting to spread his investments round about.
In the past, this lady had been able to fill in her Income Tax return, but by now she was nearing a nervous breakdown because of the present complications introduced by the Capital Gains Tax. All the details of the investments had to be given, with the prices at which they were purchased and sold, and so on. Unless one has an office, or one has a trained business mind, it is almost impossible to deal with Income Tax returns of this sort, so firms like mine and many others willingly get down to the job of trying to help these ladies and others in like straits.
I remind the Chief Secretary of another remark he made in his unfortunate speech last year:As everybody knows, with the Capital Gains Tax the real difficulties are in finding out past history, what happened to particular 1800 shares which changed their form and had various rights issues, bonus issues, and so on.I agree.The only way of preventing such trouble arising in the future is to have a full return so that all the information is available, and life will be a good deal easier in the future." —[OFFICIAL REPORT, 4th July, 1966; Vol. 731, c. 141.]Life will be easier in the future for the Revenue and everyone else if this work is done properly and efficiently. I am certain that the Revenue will be glad if it is done properly and by professional people. There is enormous waste of time by busy Revenue officials in dealing with badly completed forms prepared by individuals who have tried their best and have not been able to afford proper professional assistance. The officials of the Revenue are very willing to see people and try to help with their returns. But think of the time wasted at these interviews when people have completed their forms wrongly. All that time and trouble could be saved if the forms were properly presented by a solicitor or accountant.
The new Clause would produce that result and would be an absolutely fair provision. It would not cost the Government much. Perhaps the right hon. Gentleman will give us the figure. On balance, it would show a profit, because of all the time now wasted which it would save.
I hope that the right hon. Gentleman will move away from the question of principle, put that on one side and realise that times have changed a little since 1955 when the Report of the Royal Commission was published. Let him now accept the argument which is put, with support from both sides, that justice would be done by a more sympathetic approach on this occasion.
§ Mr. Frederic Harris (Croydon, North-West)
Many of us have battled on this policy for many a year. After the excellent speech of my hon. Friend the Member for Wycombe (Mr. John Hall) setting the matter out in detail, there is little to add. Nevertheless, we must constantly put on record our support for the policy enshrined in the new Clause. It would be only just, and it ought to be taken to its logical conclusion.
Understandably and, perhaps, unavoidably, the hon. Member for Heywood and 1801 Royton (Mr. Barnett), with his professional knowledge and experience, expressed himself as in favour of the principle of the Clause. I wondered how he would get out of voting with us when it came to the Division. Then he put out the idea of an equitable solution on the basis of allowing 50 per cent. of the charge instead of 100 per cent. I do not know how he can, in honesty, with his professional experience, advocate only 50 per cent. of his bills to his personal clients being allowed when he knows that for companies the full charge is generally allowed. However, I assume that he will sort that out in his mind somehow.
Presumably, each one of us has something of an interest to disclose, apart from a professional interest like that of the hon. Member for Heywood and Royton. If the Clause were carried, a good many Members of Parliament would in due course, and quite rightly, benefit from it. Like my hon. Friend the Member for Chippenham (Mr. Awdry), we are constantly bombarded by constituents who are, understandably, desperately worried in trying to make their tax returns. Even the most simple return is a complicated business nowadays, and the problems have been aggravated enormously by the Capital Gains Tax, which is worrying everyone a great deal.
A constituent, a coalman, came to see me the other day, and after about 20 minutes I had not found out what he wanted to ask me. He said, "I do not want to pay my Income Tax", and I replied, "That makes two of us." After a time I found that he had made himself such a nuisance to the local tax inspector in my district that the inspector had told him, "Go and see your Member of Parliament, and he will do something about Income Tax generally."
That is humourous, but we all receive numerous representations by constituents who find the situation very complicated. The answer is simplification of taxation generally. Large numbers of us have advocated such a policy for a long time, but regrettably tax returning and the whole system of taxation have become ever more complicated—certainly very much so in the past two or three years, with the new taxes that have been brought 1802 to bear, such as the Capital Gains Tax. They add considerably to the problem and highlight the need for the Government to agree to the principle again advocated in the Clause.
The difficulty of accuracy of returns was mentioned by my hon. Friend the Member for Wycombe (Mr. John Hall). It is absolutely true that people cannot be sure that they are returning their incomes correctly and have not slipped up in some way. Yet they are rather loath to turn to the accountancy profession and incur the charges which must understandably be levied. If they did turn to it in a bigger way, I wonder whether the profession as it is today could undertake the work. The tax officials frankly cannot cope, even though out of 45,000 additional civil servants a large number has gone on the Inland Revenue side.
I am sure that the accountancy profession equally would find it increasingly difficult, because I gather that most of its members are under extreme pressure. Yet, in fairness, the help needs to be given. As one or two hon. Members have already said, the charges are allowed in calculation against company profits. If they are allowed against company profits they should be allowed against personal tax returns, particularly when those returns have become so complicated.
We do not want a half basis such as the hon. Member for Heywood and Royton mentioned. That is a most unfair suggestion. Either we go for the whole thing or we do not go for it at all. I do not see how we can do it on a half basis.
Finally, I wish to say very much in support of the principle of the Clause that many people literally do not know the allowances they are entitled to claim. My hon. Friend the Member for Worcestershire, South (Sir G, Nabarro) has constantly put that point to the House of Commons, not so much in regard to M.P.s' returns as to the public as a whole. He has highlighted time and time again the fact that people are paying taxation that they should not pay.
There is no doubt that the Inland Revenue is quite innocently getting away with a tremendous taxation income to which it is not entitled. Surely it should be prepared to make it possible for people in their private circumstances to 1803 make accurate tax returns and give them a chance to make sure that they have not missed anything which they are entitled to claim? In this way the Inland Revenue's officials would be helped because they do not want inaccuracies, unfairness and injustice.
Sometimes there are suggestions that it is wrong genuinely to avoid tax that one should not have to pay. Why? People should only pay tax which the law states that they must pay. They should not, by inaccuracies and mistakes, pay money that they do not have to pay. I cannot understand that argument being constantly brought out, as if there were something heinous and wrong in making statements about not paying tax that one must not genuinely pay.
We well recall the Chief Secretary's speech last year, but we hope that he will be prepared to go along with the principle of the Clause. I concede, as did my hon. Friend the Member for Wycombe, that it may not be absolutely desirable in every way. The £40 limit may be unfair in some respects. On the other hand, if the principle is agreed the tidying up can be done later. We therefore hope that the Chief Secretary will consider the principle fairly and answer accordingly.
§ Sir G. Nabarro
This Clause, or something very like it, has been moved, if selected, during the Committee and Report stages of Finance Bills for at least the past 17 years. It is a hardy annual. I suppose that the average is every other year.
But this year my right hon. and hon. Friends have so phrased the Clause as to bring it up to date and put it fairly into contemporary fiscal conditions, including the Capital Gains Tax. Although I shall vote for the Clause, I particularly dislike subsection (4). I never believe in excluding Surtax payers from any benefit, however small. It is true that the Inland Revenue's answer would be that if a Surtax payer's liability to Income Tax is computed and his gross income assessed then the assessment of Surtax after the Income Tax figures have been struck is a 10-second operation. I therefore regret the exclusion of any tiny benefit for Surtax payers in this context as morally wrong and indefensible. I am for the Surtax payers.
1804 But having said that, I want to allude to a reference made by my hon. Friends the Members for Wycombe (Mr. John Hall) and Croydon, North-West (Mr. Frederic Harris) about the whole philosophy of avoiding tax payments legitimately. The incidents to which they both referred occurred due to a kindly Labour Member then seated on this side of the Committee intervening sotto voce in a speech of mine when I was attacking the then Tory Government for continuing Schedule A for owner-occupiers of houses.
I said, not in any boastful sense, but in a factual sense, that I never paid a penny in Schedule A, and the kindly Labour Member—I think that it was the hon. Member for Westhoughton (Mr. J. T. Price)—intervened. It is seven or eight years ago, and I have not the exact reference. He said, "How do you fiddle it, Gerald?"
I dropped my notes on the spot and went to work on him. I told the then Committee on the Finance Bill exactly how not to pay Schedule A Income Tax —and how quite legitimately not to pay it. But it was a tortuous business. During the years that followed hundreds of thousands of additional maintenance claims were put in to the tax inspectors all over the country, and the real reason why a Tory Chancellor cancelled Schedule A three years later was that the tax inspectors were sinking under the load of the additional maintenance claims that the hon. Gentleman's chance remark, "How do you fiddle it, Gerald?". promoted.
§ Mr. J. T. Price
I am very much obliged to the hon. Gentleman for giving way. As he has been good enough to refer to me in his speech, and to get the record complete, I should like him to remember that the following year I had the honour of moving from the benches opposite a suitable Amendment to abolish Schedule A. I did it much against the wishes of some of my hon. Friends. Therefore, it is on the record that I supported the abolition of Schedule A, which, in my opinion, unfairly affected a great many owner-occupiers.
§ Sir G. Nabarro
I am grateful to the hon. Gentleman. I had intended to refer to Schedule A only in passing. It was an extremely complicated exercise for the 1805 ordinary owner-occupier of a small house to compile correctly a maintenance claim under Income Tax, Schedule A.
That is a clear illustration of what happens when the popular fancy is taken as to what can be achieved by way of taxation relief if taxpayers are fully appraised as to the benefits that they can secure. Year after year the Treasury has resisted this type of proposition, for one reason. I put it fairly and squarely to the Chief Secretary. The reason why he resisted this proposition last year was simply that, if chartered accountants—he is a luminary of that profession—prepared a much larger number of taxpayers' returns for the Revenue, much larger benefits would thereby be secured by the taxpayers and overall, in the aggregation, there would be a substantial loss of revenue to the Treasury. That is why the Chancellor of the Exchequer resists this proposition and this type of new Clause year after year.
A chartered accountant preparing a taxpayer's papers will generally save him substantial sums of money. Every year I secure a reclamation of Income Tax and Surtax which I could not do for myself. I do not know enough about the taxation law to do it for myself. I can no longer compile my own tax papers. The hon. Member for Ashton-under-Lyne (Mr. Sheldon) need not assent. I know little of the tax law.
§ Sir G. Nabarro
The hon. Gentleman's knowledge is infinitesimal. I readily confess—I say this quite honestly and candidly—that I can no longer do my own tax papers. Mercifully, I am relieved from making a return under Schedule A, but I have my returns on Schedule D and Schedule E. I have at one and the same time to put on my tax return my income as a Member or Parliament, my income as a company director, my income from investments, and my income from televising, broadcasting and journalistic activities which are assessable under Schedule D. We had a lively debate last year on the contradistinctions between allowances on Schedule D and Schedule E and the need for uniformity between the two.
I return to the reference made by the hon. Member for Heywood and Royton 1806 to Section 137 of the 1952 Act. He used the word "trade". Later, he talked about the trade element and the private element in Schedule D. He gave the Committee an impression that Schedule D Income Tax payers are most largely traders. They are not. They are a very large number of people like the hon. Member for Worcestershire, South who are self-employed.
§ Sir G. Nabarro
There are quite a lot of them, self-employed.
I am assessed under Schedule D for these activities. I shall eternally be grateful to my right hon. Friend the Member for Wolverhampton, South-West (Mr. Powell), who put me up to it in 1955 when I complained to him that I could not have the cost of my Press cuttings, reporting my Parliamentary and other public activities, allowed as a charge against my Income Tax. My right hon. Friend, then Financial Secretary to the Treasury, asked my permission to send for my tax files. I said, "Of course, I have nothing to conceal from my right hon. Friend. He may send for my tax files". He sent for them. He said to me quietly in the Lobby one day, "Translate your income from television, from broadcasting and from journalistic activities, from Schedule E to Schedule D and then put in a claim for your Press cuttings against Schedule D and you will find that it is allowed". Not only did the Revenue allow it, but it gave me three years' arrears as well, thanks to my right hon. Friend.
I tell these stories this evening only because they reveal that I, as an ordinary taxpayer, was being deluded by the Revenue and deprived by it of benefits to which I was properly entitled. It was not until my right hon. Friend and all his advisers in Somerset House looked at my tax files that they caught up with the point that I was so being deprived, and they advised me how to put the matter right.
§ 7.15 p.m.
§ Mr. Eric Lubbock (Orpington)
The hon. Gentleman has been telling the Committee how he had to engage the services 1807 of professional accountants in the compilation of his Income Tax returns. Does he recall Hilaire Beloc's dictum:It is the business of the wealthy man To give employment to the artisan"?
§ Sir G. Nabarro
Yes. I hope that I am magnanimous in that sense. I did not know that quotation, but, of course, I employ an accountant.
I come to the further point which has been alluded to as equity by hon. Members on both sides. My accountants charge me 100 gns. per year for doing all my personal tax papers. They then sort out how much is attributable to Schedule 171 and charge it back against the Schedule D assessment; but they cannot do that for the Schedule E part. Chartered accountants opposite would agree with that. Even where a person is not simultaneously assessed both to Schedule D and to Schedule E, it is grossly unjust that the Schedule D taxpayer gets some kind of tax benefit which the Schedule E taxpayer does not obtain.
§ Mr. J. T. Price
There is nothing original or startling in this revelation of how the hon. Gentleman gets back on to the Schedule D wicket. If he casts his mind back, he will remember that W. S. Gilbert, the man who wrote the lyrics for Sullivan in the Gilbert and Sullivan operas which we are all familiar with, in 1897, invented the Duke of Plaza-Toro Ltd. in order to escape taxation. Many noble Lords who have followed the Duke of Plaza-Toro Ltd. in the flesh have converted themselves into limited companies for that reason. I do not know why we could not have Gerald Nabarro Ltd. as a substitute for the sort of hybrid situation he has described.
§ Sir G. Nabarro
I do not wish to be drawn into conflict with the Chair. It is relevant, because accountants advise on this kind of thing.
§ The Chairman
I have already ruled that it is irrelevant, so the hon. Gentleman is not correct in saying that it is relevant.
§ Sir G. Nabarro
In view of your Ruling, Sir Eric, I pass at once to the Capital Gains Tax.
1808 I am very glad that my right hon. and hon. Friends have included the Capital Gains Tax in the Clause. If there was any merit in the publication of the contribution by Mr. Milner in last Sunday's Sunday Times it was that it brought out once again the impossible intricacies and complexities of the Capital Gains Tax from the point of view of the ordinary taxpayer. I am not talking about accountants, professional men, wealthy people, businessmen, or the remainder. I am talking about millions of ordinary taxpayers who own assets of more than £1,000, or who own stocks and shares. The rate at which they have to pay the tax is a separate argument. I am on the point of the complexity of assessing their liability.
The Capital Gains Tax has been running for only a year or two. Already, I have received hundreds of letters from aggrieved taxpayers who are utterly incapable of assessing for themselves their liability to Capital Gains Tax. The trouble is that if they leave it to the tax man to assess, they will all be paying far more than they ought to be paying. I do not trust the Inland Revenue to do my tax papers for me. I would not trust them to do anybody else's tax papers for them. I believe that accountants are the only people suitably qualified to guide taxpayers as to the sums they should pay in Income Tax, Surtax and Capital Gains Tax and that the average taxpayer is utterly incapable of making a computation as to his liability for Capital Gains Tax.
In all those circumstances, I hope that my right hon. and hon. Friends will press this matter to a Division if there is not a sympathetic reply from the Treasury.
We propose to keep on with this year after year. As the Chief Secretary has been instrumental in making our taxation system so very much more complicated than it was before he took office—notably with the addition of Capital Gains Tax —as the next General Election approaches I shall call on my party to enunciate the principle more widely and put into its Manifesto that we believe in the accountancy profession guiding taxpayers and that there should be a tax concession for taxpayers to cover those professional charges entailed in returning to the Revenue a proper and accurate return the first time, all of which would save large 1809 sums, from a public point of view, by enabling tax inspectors to deal with tax papers much more expeditiously than they do at present.
§ The Chief Secretary to the Treasury (Mr. John Diamond)
I rise partly because we have had a good debate on this topic and partly because it has been debated many times before. Individual Members may wish to continue the debate, but I hope not.
As I say, we have debated this matter many times. However, having listened very carefully in particular to the long, well-informed, detailed and outspoken speech of the hon. Member for Worcestershire, South (Sir G. Nabarro), I am bound to draw the conclusion that I have not heard a single word which was relevant to the Clause.
The hon. Gentleman and previous speakers directed attention to whether Income Tax returns, returns of Capital Gains Tax and other returns would be more competently completed if professional men were employed on their behalf. Nobody—certainly not I—would know enough about it to challenge that statement. However, we are not concerned with that. We are concerned with whether, where it does happen, it is proper and appropriate that the charge incurred should be a deduction for tax purposes.
I have not heard one word in the hon. Gentleman's speech, and very few words in other speeches, directed to this topic, so it is convenient to draw the attention of the Committee to the essential matter.
§ Mr. Diamond
I am making no reflection on the Chair. The Chair has been good enough to allow the discussion. That is the end of the matter.
§ Mr. Diamond
I am going further. I am putting forward an argument. I am saying that I have listened carefully to what was said by the hon. Member for Worcestershire, South and, in my opinion, he did not deal with the essential point. The Clause deals with many 1810 points about which it would not be irrelevant to make a comment, but that does not get to the heart of the matter. The heart of the matter is whether these charges should be a deduction for tax purposes.
Therefore, my first duty is to enunciate the principle, then to examine the practice, and then to see how this ties up with the interesting speeches which have been made on the topic.
The principle is very simple: that expenditure incurred in earning profits or expenditure incurred in earning income is a deduction from those profits or from that income. That is the first principle of our taxation affairs. Expenditure incurred out of taxed profits and personal expenditure incurred out of taxed income is one of the ways in which we spend the money which is free for us to spend and has nothing to do with the Inland Revenue.
We spend money going to the dentist or having music lessons or improving ourselves in a whole host of ways. We may spend money on all sorts of professional services, and it may well be that those professional services count as taxable receipts in the hands of the professional men concerned. That does not affect the principle on which the whole of our taxation system is based: that expenditure in earning profits is a deduction from those profits for tax purposes. Having arrived at the taxed profits and having arrived at the taxed personal income, what is done with those sums is a matter for the individual and is not of interest to the Inland Revenue.
There is no question whether in certain cases a tax return should be prepared by a professional man and whether it would be better prepared and what proportion are already prepared. The greater proportion of personal Income Tax returns are not prepared with the assistance of professional men. They are prepared by individuals who incur no professional fees in their compilation. That is not the question here. The question is: Is it right to say that this particular kind of personal expenditure which is defined in the Clause should be a deduction for tax purposes? This is a fundamental principle and one has to be sure that a proposal which is put forward coincides with, or is not wholly irreconcilable with, that principle before accepting it. I do not think that is so here.
1811 It is the case that the law, the expression of the law, by eminent judges and the expression of the view of what the law should be by the Royal Commission all tally in saying that an expense of this kind—professional fees paid for preparing a personal Income Tax return—is not a deduction from the income which is earned and therefore should not be allowed for tax purposes.
I have been challenged by the hon. Member for Chippenham (Mr. Awdry) who said he hoped that he would hear no more about the principle having regard to what the Royal Commission said. I can only say that I do not think he gave himself time to read the Royal Commission's Report in full.
In paragraph 928 of the Report the Royal Commission said:No deduction is explicitly allowed for the expense of preparing tax returns. We should not see anything singular in this by itself. Any effective control of such expense would be out of the question, and there is no general principle that would require a taxpayer's taxable income to be affected by the fact that he may have incurred some expense in performing his general duty of making a proper return.They examined this and went on to say, in paragraph 929:We decided against recommending this"—that is to say, making an allowance. The leading case on the matter is Smith's Potato Estates, where Lord Porter explained the position and came to the same conclusion.
The law is applied in the way I have described in all cases where it is practicable so to apply it. Therefore, I have only to deal with the one case where it is not so applied, which, as my hon. Friend the Member for Heywood and Royton (Mr. Barnett) made clear, is where it is impossible to apply it because it is impossible to define how much of an expense incurred on a variety of purposes relates to one of those purposes. He made the case himself by quoting the example of the small business man. He said that thousands of them have their accounts prepared professionally, and would maintain that they do it only for tax reasons and, therefore, the element in the accountancy charges relating to business purposes as opposed to tax purposes would be 0 per cent. Others 1812 would come forward and say that they have accounts prepared only for business reasons and would claim 100 per cent. In short, the argument would be between 0 and 100 per cent.; in other words, between the proportion of the accountancy fees incurred in preparing accounts for the purpose of illuminating the business position or for the purpose of establishing the taxable profit. It would be impossible to divide it.
For that reason, we have accepted the illogical but nevertheless practical proposition that, as it is impossible to say which part of the professional fee for preparing a set of accounts and the taxable figure on those accounts relates to business purposes and what part to taxation purposes, the generous way is to say that the whole amount should be regarded as a deduction from profits.
On this last Clause in the Committee stage of the Finance Bill, the Committee is trying to drive me, the representative of the Revenue, away from that generous and magnanimous point of view. I refuse to be so driven. I do not think that the logical conclusion in carrying out the principle as enunciated would drive us to say that only a proportion of the amount of the accountancy charges paid by the business should be allowed for tax purposes. We should not do that and, therefore, the Government cannot approve of this new Clause.
§ Mr. Gower
I am disappointed at the Chief Secretary's reply. He was at pains to explain the law, but we know the law about these cases. We want the law altered.
No one with experience of these matters can deny that thousands of people in this country pay more tax than they should and more than they were intended to pay when successive Chancellors devised our taxes. If the Chief Secretary doubt that, I invite him to collect from his tax inspectors the Income Tax returns of persons in approximately similar economic positions and with the same number of dependents. In some circumstances, he will find that, if they do not have professional advice, they pay very different amounts of taxation.
It is desirable that the citizens of this country should pay the tax which they are properly due for by reason of their 1813 incomes and the sophisticated allowances which have been devised. They should not pay any more. It is undesirable that there should be divergences in the amounts paid by people with the same incomes, dependents and entitlement to allowances.
As a solicitor, I have known a person pay tax on approximately the same income for a number of years, with assistance from Revenue officials. When I have advised such a person to see an accountant, in nearly every case that person has had some reduction in his taxes. That is a situation which is neither healthy nor calculated to induce in the minds of citizens a proper respect for the tax law. It would be a desirable reform if persons were encouraged to obtain professional advice. The Chief Secretary tells us that only a minority of persons making personal returns have professional advisers and that the majority of returns are made individually without such assistance.
Then he made a somewhat technical objection to the speeches which we have heard in support of the Amendment by suggesting that they were directed at the accountant's fee and not at the concession sought for that fee. However, if he reconsiders this, he will recognise the case which we are making. We believe that the taxpayer should be encouraged to obtain the best possible advice on matters of this kind. He should be encouraged to obtain all the allowances relevant to his circumstances and to pay no more than his proper tax. There are thousands of people who are paying too much tax, even considering Income Tax alone. When the new complications of the Capital Gains Tax are included, one can only assume that the disparity will increase. It is a position which we should not tolerate, and, therefore, the new Clause deserves full support.
§ Mr. John Smith
I must speak, though briefly, because I thought that the Chief Secretary's reply was rather casuistical. He based his case on the proposition that expenses allowable for tax must be incurred in earning profits. I am not an accountant, but I am sure that we all know about the case of Usher's Wiltshire Brewery v. Bruce and all that. Yet auditors' fees are allowed, trust income fees are allowed, and the costs of having 1814 valutions made for the purpose of Capital Gains Tax are allowed. None of these are incurred in earning profits.
However, another and very much more relevant test which the Revenue apply to expenses is whether they are necessary. A number of hon. Members have gone over the ground of the complications of the modern tax system and whether individuals should be expected to tackle them for themselves. On that score alone, I should have thought that these expenses are necessary. But they are necessary for another reason as well.
The Government's attitude might be reasonable if the Revenue could be relied upon invariably to be impartial, fair and objective. That is the aim, as the general rule, but it is not always so. One cannot rely on it. I have, as always, a letter from a constituent of mine. He is a solicitor, and he writes:I think it is incumbent on the Revenue to be fair and objective. But in a case which I have on at the moment I have discovered quite by chance that the Shares Valuation Division have at one and the same time and with reference to the same class of share in the same company been using completely contradictory arguments to me and to another firm of solicitors. In my case, they are trying to value the shares down with a view to future Capital Gains Tax, and in another case, they are trying to value the shares up for Estate Duty purposes, and many of the arguments which I have used in support of my valuation have been adopted and used against the advisers in the other case. The climax of this was that the Shares Valuation Division informed the other advisers that no less than 10s. a share would be accepted for Estate Duty purposes while in the same month they were seeking to maintain that the self-same shares were only worth 8s. 3d. to me.That should show that in modern circumstances the taxpayer cannot defend himself on his own.
There is also a second and different reason, which has not been mentioned, why the Clause is important, and it has nothing to do with the individual. There is a growing habit among Governments to unload the cost of administering taxes on to the taxpayer, and hence they lose sight of the true cost of a tax. The Clause will help to correct that. The loss of revenue, not so much from informing taxpayers what they are entitled to, but from deducting these charges from the taxpayers' gross revenue, will help to bring home to the Government the true cost of administering taxes. At present they 1815 ignore this. They ignore both aspects of the problem.
Shifting the burden of administering a tax on to the shoulders of the taxpayer not only conceals from the Government the cost of the tax to the economy, but distorts the true yield of a tax and makes it look larger that it is. We had a ludicrous example of this in this Committee a few days ago when we were discussing stamp duty on cheques, a duty which raises £9 million a year, but which costs the banks so much to collect that their profits, on which they pay tax, are reduced by a greater amount, so that the stamp duty on cheques probably involves the Revenue in a net loss.
The same thing undoubtedly happens with other forms of stamp duty. For example, the fees on conveyances are fixed fees and, therefore, the cost of getting a document stamped would, if saved, be added to the earnings of the partners in the firm who are probably taxed at very high rates. It is almost certain that many forms of tax appear to show a good yield to the Revenue, and are put there in the published statistics; but they are offset against other forms of taxation which they cause to fall, there is no net yield to the Revenue at all. The more we can bring home to the Government the actual cost to the Revenue and to the economy of administering a tax, the better are our chances of getting a more sensible and less wasteful taxation system.
§ 7.45 p.m.
§ Mr. John Hall
We have had a very interesting debate. I think that hon. Members on both sides have made a very strong case for the Chief Secretary to accept the Clause. In spite of that, we have had a totally disappointing and stonewalling reply. Had he, in his previous status, been on this side of the
§ Committee, we would have had a very different speech indeed.
§ The right hon. Gentleman referred to the Royal Commission, but he did not repeat that part of paragraph 929 which said that in coming down against recommending a general allowance it was only on the balance of argument. That was 10 or 11 years ago. Since then, and especially during the last two years, the position of the taxpayer has become intolerably complicated. There is more need than ever before for professional advice and for making the charges allowable.
§ I remind the right hon. Gentleman that even Antonio, when he was called on by Shylock to pay his pound of flesh, found it necessary to employ legal advice to avoid losing his liquid assets. I suggest to the right hon. Gentleman that there is a very good case for this today.
§ Mr. Diamond
Is the hon. Gentleman suggesting that that was allowed, and that it was deductible in any sense?
§ Mr. Hall
He avoided losing them, but only by paying for legal advice.
The right hon. Gentleman has stonewalled in the past. He opposed Amendments to the 1965 and 1966 Finance Bills, yet in the following years he introduced Amendments giving away what he had previously opposed. I hope that that is a precedent for this Clause, and that next year the Government will table an identical one to give us what we want. However, as the right hon. Gentleman is not prepared to give it to us tonight. I can only advise my right hon. and hon. Friends to take the matter to a Division.
§ Question put, That the Clause be read a Second time:—
§ The Committee divided: Ayes 103, Noes 191.1819
|Division No. 380.]
|Alison, Michael (Barkston Ash)
|Allason, James (Hemel Hempstead)
|Cunningham, Sir Knox
|Beamish, Cot. Sir Tufton
|Currie, C. B. H.
|Dalkeith, Earl of
|Hall, John (Wycombe)
|Boyle, Rt. Hn. Sir Edward
|d'Avigdor-Goldsmid, Sir Henry
|Harris, Frederic (Croydon, N.W.)
|Brinton, Sir Tatton
|Deedes, Rt. Hn. W. F. (Ashford)
|Buchanan-Smith, Alick (Angus, N&M)
|Heald, Rt. Hn. Sir Lionel
|Buck, Antony (Colchester)
|Higgins, Terence L.
|Bullue, Sir Eric
|Elliott, R. W. (N'c'tie-upon-Tyne.N.)
|Burden, F. A.
|Hobson, Rt. Hn. Sir John
|Hogg, Rt. Hn. Quintin
|Morgan, Geraint (Denbigh)
|Morrison, Charles (Devizes)
|Stoddart-Scott, Col. Sir M. (Ripon)
|Jenkin, Patrick (Woodford)
|Munro-Lucas-Tooth, Sir Hugh
|Taylor, Sir Charles (Eastbourne)
|Jennings, J. C. (Burton)
|Nabarro, Sir Gerald
|Taylor, Edward M.(G'gow,Cathcart)
|Noble, Rt. Hn. Michael
|Temple, John M.
|Kaberry, Sir Donald
|Thatcher, Mrs. Margaret
|Turton, Rt. Hn. R. H.
|King, Evelyn (Dorset, S.)
|Orr-Ewing, Sir Ian
|Knight, Mrs. Jill
|Osborn, John (Hallam)
|Ward, Dame Irene
|Lloyd, Ian (P'tsm'th, Langstone)
|Osborne, Sir Cyril (Louth)
|McAdden, Sir Stephen
|Page, Graham (Crosby)
|Macleod, Rt. Hn. lain
|Page, John (Harrow, W.)
|Wells, John (Maidstone)
|Pearson, Sir Frank (Clitheroe)
|Wllitelaw, Rt. Hn. William
|Wills, Sir Gerald (Bridgwater)
|Wilson, Geoffrey (Truro)
|Maxwell-Hyslop, R. J.
|Pink, R. Bonner
|Wood, Rt. Hn. Richard
|Maydon, Lt.-Cmdr. S. L. C.
|Mills, Peter (Torrington)
|Rossi, Hugh (Hornsey)
|Mills, Stratton (Belfast, N.)
|TELLERS FOR THE AYES:
|Mr. David Mitchell and
|Shaw, Michael (Sc'b'gh & Whitby)
|Mr. Anthony Grant.
|Sinclair, Sir George
|Fletcher, Raymond (Ilkeston)
|Mahon, Simon (Bootie)
|Allaun, Frank (Salford, E.)
|Foot, Michael (Ebbw Vale)
|Marsh, Rt. Hn. Richard
|Atkins, Ronald (Preston, N.)
|Atkinson, Norman (Tottenham)
|Mendelson, J. J.
|Bacon, Rt. Hn. Alice
|Bagier, Gordon A. T.
|Gray, Dr. Hugh (Yarmouth)
|Miller, Dr. M. S.
|Grey, Charles (Durham)
|Mitne, Edward (Blyth)
|Griffiths, David (Rother Valley)
|Mitchell, R. C. (S'th'pton, Test)
|Griffiths, Rt. Hn. James (Llanelly)
|Morgan, Elystan (Cardiganshire)
|Bennett, James (G'gow, Bridgeton)
|Hale, Leslie (Oldham, W.)
|Morris, Alfred (Wythenshawe)
|Hamilton, James (Bothwell)
|Morris, Charles R. (Openshaw)
|Bishop, E. S.
|Hamilton, William (Fife, W.)
|Harrison, Walter (Wakefield)
|Noel-Baker, Francis (Swindon)
|Heffer, Eric S.
|Braddock, Mrs. E. M.
|Brown, Hugh D. (G'gow, Provan)
|Callaghan, Rt. Hn. James
|Cant, R. B.
|Houghton, Rt. Hn. Douglas
|Howarth, Robert (Bolton, E.)
|Owen, Dr. David (Plymouth, S'tn)
|Pannell, Rt. Hn. Charles
|Concannon, J. D.
|Parkyn, Brian (Bedford)
|Hughes, Emrys (Ayrshire, S.)
|Craddock, George (Bradford, S.)
|Pearson, Arthur (Pontypridd)
|Irvine, A. J. (Edge Hill)
|Crosland, Rt. Hn. Anthony
|Johnson, James (K'ston-on-Hull, W.)
|Price, Thomas (Westhoughton)
|Cullen, Mrs. Alice
|Johnston, Russell (Inverness)
|Price, William (Rugby)
|Jones, Dan (Burnley)
|Davies, Dr. Ernest (Stratford)
|Jones, J. Idwal (Wrexham)
|Robertson, John (Paisley)
|Davies, G. Elfed (Rhondda, E.)
|Jones, T. Alec (Rhondda, West)
|Rogers, George (Kensington, N.)
|Davies, Ednyfed Hudson (Conway)
|Ross, Rt. Hn. William
|Davies, Ifor (Gower)
|Kerr, Russell (Feltham)
|Shaw, Arnold (Ilford, S.)
|Davies, S. O. (Merthyr)
|Lestor, Miss Joan
|Shore, Peter (Stepney)
|Short, Rt. Hn. Edward(N 'c' tle-u-Tyne)
|Short, Mrs. Renée (W'hampton.N.E.)
|Diamond, Rt. Hn. John
|Silverman, Julius (Aston)
|Lyon, Alexander W. (York)
|Silverman, Sydney (Nelson)
|Lyons, Edward (Bradford, E.)
|Mabon, Dr. J. Dickson
|Dunn, James A.
|Dunwoody, Mrs. Gwyneth (Exeter)
|Steel, David (Roxburgh)
|Dunwoody, Dr. John (F'th & C'b'e)
|Steele, Thomas (Dunbartonshire, W.)
|Macdonald, A. H.
|Edwards, Rt. Hn. Ness (Caerphilly)
|Symonds, J. B.
|Mackenzie, Gregor (Rutherglen)
|Thorpe, Rt. Hn. Jeremy
|Mackintosh, John P.
|Evans, loan L. (Birm'h'm, Yardley)
|McNamara, J. Kevin
|Urwin, T. W.
|Varley, Eric G.
|Fitch, Alan (Wigan)
|Mahon, Peter (Preston, S.)
|Wainwright, Edwin (Dearne Valley)
|Wainwright, Richard (Colne Valley)
|Williams, Alan (Swansea, W.)
|Walden, Brian (All Saints)
|Williams, Clifford (Abertillery)
|Walker, Harold (Doncaster)
|Wilson, William (Coventry, S.)
|Winstanley, Dr. M. P.
|TELLERS FOR THE NOES:
|Watkins, Tudor (Brecon & Radnor)
|Winterbottom, R. E.
|Mr. Harry Gourlay and
|Woodburn, Rt. Hn. A.
|Mr. Joseph Harper.