HC Deb 28 June 1967 vol 749 cc545-61
Mrs. Margaret Thatcher (Finchley)

I beg to move Amendment No. 74, in page 70 line 35, to leave out paragraph 2.

The Chief Secretary will remember that when I moved the Amendment in Committee I asked him to reconsider the inclusion of the paragraph in the Bill. I do not think that this is an occasion for me to rehearse the arguments I put forward then. I should be grateful if he could report to the House what he has decided about the Amendment, whether he will propose any changes in a forthcoming Finance Bill, and his conclusions about top slicing and the inconsistencies between last year's Act and his proposals in the Bill as they apply to pension and annuity funds.

Mr. Diamond

I cannot recommend the acceptance of the Amendment. I shall deal with it as simply as I can, but we now move from the absolutely clear and pellucid provisions of the Bill into matters which are somewhat complicated.

The background of the Amendment is that the Life Office's Association has been pressing for a larger allocation of franked income to shareholders, and the corollary is a smaller liability to Schedule F tax on the dividends paid than is the rule under the Bill. We are concerned here with proprietary life assurance companies who must pay out their profits partly to shareholders and partly to policy holders. The problem relates to the allocation of franked investment income. We take the view that in the absence of any guidance to the contrary, and as there is no logic in having anything other than what we propose, the sensible way of dealing with the matter is to apportion franked investment income in the same way as the company apportions its profits as between those two groups.

That sounds good common sense. There is nothing against it, and that is what is in the Bill. The hon. Lady asked us to look at the matter again and I proposed to receive once more the representatives of the life assurance companies. I was glad to do so, and to hear their representations. But on that issue I am confirmed in the view which we previously held that this is the commonsense way of dealing with the matter. No view has been expressed by any Body—with a capital B—which recommended otherwise, and, therefore, it would be wrong to suggest that we should depart from our previous view.

The hon. Lady reminded me that she referred to certain inconsistencies, which I have also considered. I was the more easily able to consider them in cold print than in the words she used at the time. The inconsistencies have also been considered with the representatives of the association, as a result of which I wrote to its chairman. I shall not quote the whole letter, but perhaps I should repeat these words: … I understand that the Inland Revenue have decided that the provisions in the Finance Bill and in last year's Finance Act can be interpreted in a way which meets your difficulty. I thought that it was as well to put that on the record to show the hon. Lady that this is not an insuperable difficulty. The inconsistency arises out of a possible interpretation; that interpretation does not hold the day, and, therefore, there is no need for any alteration.

In those circumstances, I hope that the hon. Lady will feel that we have done the best we can by receiving a deputation, which corroborated what she said in Committee, and to pay full regard to it. Nevertheless, I hope that she will believe that the solution we propose in the Bill is perhaps the better one, and that in those circumstances a great deal would not be achieved by pressing the Amendment.

Mrs. Thatcher

There is clearly a very fundamental difference between us on this. As my right hon. Friend and I will probably deal with it in three or four years' time, perhaps we had better leave it until then.

Mr. Deputy Speaker

Does the hon. Lady wish to withdraw the Amendment?

Mrs. Thatcher

No, Mr. Deputy Speaker.

Amendment negatived.

Mr. Deputy Speaker

The next Amendment to be considered is Amendment No. 49. I gather that it will be for the convenience of the House if, at the same time, we consider Government Amendment No. 50, Amendment No. 51 in the name of the right hon. Member for Enfield, West (Mr. Iain Macleod), in page 72, line 19, to leave out from 'only' to the end of line 22, and Government Amendments Nos. 52, 53, 54 and 67.

Mr. Diamond

I beg to move Amendment No. 49, in page 72, line 19, after 'shall' to insert 'not'.

We are dealing with a group of Amendments designed to remove certain difficulties which have arisen in connection with the tax treatment of inter-group dividends and inter-group transfers of assets. I again refer to what the hon. Member for Wanstead and Woodford (Mr. Patrick Jenkin) said last night about our respective responsibilities. He invited us to move towards removing impediments and difficulties in the way of genuine transactions and somewhat away from anti-avoidance provisions.

The background to the Amendments is that dividends paid by a subsidiary to its parent can be paid in full without deduction of Income Tax, but where the dividends exceed what are called the post-acquisition profits—the profits made since the parent company acquired the subsidiary—the tax deducted cannot be set off against the tax for which the company must account when it pays its own dividends.

These limitations were part of the Inland Revenue's defence against dividend stripping, with which the House has been concerned for many years. I think that this is the first time a Treasury Minister has come to the Box to relax the provisions rather than to tighten them. I hope that in the course of the years we shall be seen to have acted wisely. That is the first part with which these Amendments deal—the transfer of dividends.

5.0 p.m.

The second part relates to the transfer of the assets. If the market value of an asset transferred by a company to a shareholder exceeds the consideration passing, then the excess is to be treated as a distribution and Schedule F Income Tax, which is the relevant tax on distribution, is to be charged as though the dividend had been paid accordingly. This again was a necessary defence against avoidance.

This provision has been criticised as being unnecessarily wide in its application to groups of companies. We have examined the matter very carefully and have concluded that some relaxation can safely be made in both these types of case. Accordingly, the Amendments provide that dividends can be paid without deduction of tax and transfers of assets can be made tax free where both companies are members of the same group.

I should add that this easement does not destroy the protection which is essential to the Revenue in cases where dividend stripping transactions are entered into for avoidance purposes. For example, therefore, it will not have effect where the recipient company is treated as a dealer in securities, and it is necessary to make certain consequential changes in the Capital Gains Tax provisions.

I hope that I have made it clear that the reason for the Amendment is to provide a relaxation which has been urged upon us both by representatives of industry and by the accountancy profession to remove impediments to genuine transactions. We have, we hope, maintained proper protection of the Revenue while at the same time affording the necessary relaxation. The other Amendments all fall into line. I can, of course, give any detail that is required, but I think that, broadly speaking, the explanation I have given is sufficient and I hope that the House will therefore be good enough to give us the Amendments.

Mr. Patrick Jenkin

I am sure that it will not have escaped the notice of the House that Amendment No. 49 is the only Amendment in the whole of the Report stage and Committee stage on which the two leading names are those of the Chancellor of the Exchequer and my right hon. Friend the Member for Enfield, West (Mr. Iain Macleod). This, of course, indicates that this was an Amendment that we tabled in Committee. The Chief Secretary agreed to look at it. We have tabled it again and have been rewarded by having the Chancellor of the Exchequer putting his name at the head of the list of proposers. I shall not say more about it than that. This would also have happened to Amendment No. 50 if we had got it right.

I want to ask in particular about Amendment No. 54. The right hon. Gentleman thinks that this is the first occasion that any Treasury Minister has come to the House to propose what appears at first sight to be a relaxation of the provisions affecting dividend stripping. It was, therefore, right that we on this side of the House should look at the Amendment with extreme care—perhaps cynicism is too strong a word but certainly we went through it very carefully. I should be grateful if the right hon. Gentleman will clear up a doubt which has entered my mind, at any rate.

The background to this lies in Section 65 of the Finance Act, 1965, which dealt with the question of dividends paid out of pre-acquisition profits to a shareholder owning more than 10 per cent. of the particular category of shares concerned. In effect, it is provided, in the case of a company which is not a share-dealing company, that the excess of dividend over what could have been paid out of the current year's profit and what therefore is presumed to be paid out of pre-acquisition profit, is to be treated as capital distribution for the purposes of the Capital Gains Tax. That comes under paragraph (3) of Schedule 7 of the 1965 Act.

This means, therefore, that there is here a liability to Capital Gains Tax in respect of dividend or the relevant distribution which might amount to the whole of it if the company made a loss in the period in question. Amendment No. 54 removes the word "net" from the phrase, "net relevant distribution". At first sight this would appear to be an inevitable corollary, in effect, to what one would have as a result of the removal on grouping notice dividends paid gross.

The question which arose was whether this would mean that the gross dividend would attract the charge for Capital Gains Tax and in what possible circumstances could a company wish to pay the dividend gross if the result were going to be an additional liability to Capital Gains Tax that it might not otherwise have borne. In other words, though, on the face of it, this Amendment looks like a relieving provision, is there not a sting in its tail? The point to make is that this is, of course, as is so much of this amending legislation, retrospective. Paragraph (3) of Amendment No. 54 says: The said section 65 shall be deemed always to have had effect subject to this paragraph …". If the effect of the removal of the word "net" from Section 65(3) of the 1965 Act is, in the circumstances of the case, to increase the charge to Capital Gains Tax, this is something that we would look at with a very jaundiced eye. I recognise that it is a fair point to make that companies do not have to elect to have the dividend paid gross, that it is a matter of option. But the right hon. Gentleman will remember that, under the Schedule which deals with grouping notices, a grouping notice cannot take effect in respect of any dividend paid earlier than three months after the date of the giving of the notice. There again, it is difficult to see how the retrospective operation of this provision can have any effect if a notice cannot have been given until this Bill has become law, and the notice itself cannot have any retrospective effect. Are there circumstances in which this retrospective charge could apply?

This is a complicated matter and I am not certain what the effect of the Section can be in the circumstances I have described. I should be grateful to the right hon. Gentleman if, by permission of the House, he could go into this a little more fully and explain, first of all, whether this means that Capital Gains Tax will be charged on the gross amount of the dividends if the company elects that the dividend shall be paid gross and, secondly in what circumstances can this have effect on Capital Gains Tax being charged retrospectively and, if not, what is the purpose of the words in Amendment No. 54: The said section 65 shall be deemed always to have had effect subject to this paragraph …". While we welcome the relaxation, if relaxation it be, we would look with some suspicion if it were in the form of a retrospective charge to companies which would not have applied if this provision had not been in the Bill.

Mr. Diamond

The steps in the argument put by the hon. Member for Wanstead and Woodford (Mr. Patrick Jenkin) are perfectly logical as far as they go. The reason for excluding the word "net" is that "gross" shall have effect, and the hon. Gentleman realises the reasons for which a gross dividend should be added back whereas previously the net dividend would have been added back. But to put the whole thing in perspective, I would point out that this provision, not in every single case but in most cases, would be of benefit to the taxpayer, having the effect of reducing Schedule F taxation. The responsibility of the Revenue is to see that those circumstances which are genuine business transactions are assisted while those which are, or may well be, tax avoidances are not assisted. The provisions which we have will apply in that way. In most cases where the new provisions apply, the adjustment will not lead to a capital gains charge.

These Amendments deal with two aspects. One is the Corporation Tax aspect of transfer of dividends and the other is the Capital Gains Tax aspect of transfer of assets at less than full value.

On the first part we have met everybody's possible reasonable desires. On the second part there are many difficulties and complexities and, indeed, pitfalls. I could have handled the matter by saying to the hon. Member for Wanstead and Woodford that we must examine a little more fully the Capital Gains Tax aspect of everything and, therefore, we are not ready to bring forward this year any proposals.

However, I thought it better to bring forward proposals which were wholly satisfactory to the Opposition on Corporation Tax but which might be somewhat less than wholly satisfactory, although beneficial by and large, on Capital Gains Tax, with the further statement that this does not necessarily represent the end of the road concerning assistance on Capital Gains Tax. We would like to examine this further. If adjustments are required in a year's time we would be glad to make them, but we are not saying that it may not turn out that way.

Mr. Patrick Jenkin

By leave of the House, I would press this again, because the Chief Secretary has not dealt with the precise point. Sub-paragraph (2) of this new paragraph which the Government Amendment 54 comprises deals with Section 65(3) of the 1965 Act. This, as I indicated, is the one which charges to Capital Gains Tax, as Section 65 originally stood, the net amount of the relevant distribution, because it says that it is to be treated as a capital distribution within the meaning of Part III of the Act. If one removes the word "net" it means that it is the gross dividend which now is to come within the charge to Capital Gains Tax. The Chief Secretary has confirmed that.

The question then is whether this can have any retrospective effect. Subparagraph (3) of paragraph 4 says, The said section 65 shall be deemed always to have had effect subject to this paragraph …". Then there is the usual provision about adjustments which must be made to take account of this. Yet the grouping notice, under Section 48(3) of the 1965 Act, can only take effect more than three months after the giving of the notice. Therefore, although one's suspicions are aroused that there may be a retrospective charge to a Capital Gains Tax because the amount will be charged on the gross and on the net dividend, it is difficult to see in practice how this could arise. If a grouping notice could not have been given until after this paragraph is enacted, how could this arise? Can the Chief Secretary confirm that there is no possibility of a retrospective charge to Capital Gains Tax? If so, what is the purpose of paragraph 3? Why is this written back to 1965?

Mr. Diamond

The logic and the practical issues involved would lead to the conclusion which the hon. Gentleman wishes to draw, namely, that there is unlikely to be any retrospection. It is difficult to see how it could arise. He has asked me about the effect of particular words. I will give very careful consideration to what the hon. Gentleman said and I will write to him if there is any question of retrospection in the sense that this is retrospectively adding to the burden of taxation. Retrospectively adding to the relief of the taxpayer is a matter on which he normally presses me very hard, and that may arise. I do not think there is any question of retrospection in the sense of adding to the burden of the taxpayer, but there may be retrospection adding to the relief of the taxpayer. If there is any question of retrospection adding to the burden of the taxpayer I will immediately draw it to his attention.

Amendment agreed to.

Further Amendments made: No. 50, in page 72, line 19, leave out from 'distribution' to end of line 22.

No. 52 in line 40, after 'shall', insert 'not'.

No. 53, in line 40, leave out from 'distribution' to end of line 43 and insert: (4) If any amount would, but for sub-paragraph (2) or (3) above, be treated as, or as part of, a distribution made in or after the year 1966–67 and would as so treated constitute also the net amount of a relevant distribution within the meaning of section 65 of the Finance Act 1965 (dividend stripping) then, for the purposes o corporation tax in respect of any chargeable gains, that amount shall be treated as if it were a capital distribution (within the meaning of Part III of the Finance Act 1965) received in respect of the holding. (5) Sub-paragraphs (2) and (3) above shall not affect the meaning of 'distribution' for the purposes of paragraphs 5, 6(1) and 7 of Schedule 17 to the Finance Act 1965 (dividend stripping: relation of distributions to profits), except so far as the said sub-paragraphs (2) and (3) relieve the company from liability to account for income tax otherwise falling under paragraph 5(1) of the said Schedule 17 to he included in a distribution.

No. 54, in line 46, at end insert:

Dividend stripping

4.—(1) Section 65(6) of the Finance Act 1965 (election for treatment of dividends as group income: exclusion of relevant distributions) shall cease to have effect.

(2) Section 65(3) of the Finance Act 1965 (relevant distribution received by a company which is not a dealer: net amount of relevant distribution to be treated as a capital distribution in respect of the holding) shall apply to group income as if in the phrase 'the net amount of the relevant distribution' the word 'net' were omitted.

(3) The said section 65 shall be deemed always to have had effect subject to this paragraph, and there shall be made all such adjustments by way of discharge or repayment of tax as are necessary to give effect to its provisions.—[Mr. Diamond.]

5.15 p.m.

Mrs. Thatcher

I beg to move Amendment, in page 72, line 46, at the end to insert: (5) The said Schedule 11 shall have effect subject to the following amendments—

  1. (a) after paragraph 3(1) of that Schedule there shall be inserted the following new paragraph:—
    • '(1A) In the case of any share capital issued before 6th April 1965 which on that date had attached to it a term providing that, if the share capital was redeemed or repaid, a premium shall be payable the amount of the premium shall on redemption or repayment be treated as repayment of capital'.
  2. (b) In paragraph 3(2) of that Schedule for the words 'sub-paragraph (1)' there shall be substituted the words 'sub-paragraphs (1) and (1A)'.
This Amendment concerns the treatment for tax purposes of a premium paid on the redemption or repayment of shares which were issued before 6th April, 1965.

The Chief Secretary will be aware that it was frequently the practice to issue shares such as preference shares on terms that a premium would be paid when those shares were redeemed. For example, a particular class of preference shares may have an issue price of 20s. but a redemption price of 22s. namely, a premium of 2s. per share, when the shares were redeemed.

Before the 1965 Act that premium would have been treated both in fiscal law and in company law as a repayment of capital. The entire payment had the quality of capital both for taxation purposes and for company purposes.

When the 1965 Act came in, the treatment of that premium was altered. It would have been open to the Government at that time still to retain the nature of the premium as capital, in which event it would have been liable to the new Capital Gains Tax. Under the suggested Amendment the premium would still be liable to Capital Gains Tax, but it would retain its quality as a capital payment. However, in the 1965 Act the Government treat the premium on these shares as a distribution by the company. That changed the quality of the payment and it became an income payment liable to have Income Tax deducted from it when it was paid to the shareholder.

This has raised a number of problems for investment trusts which have to keep their capital and income separate. We are suggesting that on the strictly limited number of shares that were issued before 6th April, 1965 the premium should be treated as a capital payment.

There can be no question of my having to meet the argument that a company chose this method of issuing shares in order to avoid a particular tax, because the tax which gave rise to the difficulty was not in existence until 1965. Pre-1965 issues cannot have been made to avoid the Act, which did not come into existence until after that date of issue, and so there can be no question of tax avoidance here.

The 1965 Act has led to very great practical difficulties. Making the premium distribution has meant that one has to decide the precise amount which is liable as income to have Income Tax deducted from it. As the Chief Secretary probably knows, shares are not always issued at the same price. The same share can be issued at different times at different prices, and frequently this is so. Therefore, when it comes to calculating the precise amount of the premium from which tax is to be deducted, it is not possible to identify the issue price with certainty. Indeed, it is not possible to identify it at all.

The company is therefore left with a certain difficulty. If it takes the lowest issue price, in which case one would get the maximum premium and the maximum deduction of tax from the Exchequer's point of view, the person owning the shares can go against the company if he happens to have paid rather more than that for his shares in the first place. If the highest issue price is taken to be that which should be deducted from the repayment price, it would then be an admission by the Revenue that the terms of the Act were virtually unworkable.

That is the simple case where there is an issue at a number of different prices, but there are various other complications which can occur. There may be an amalgamation of two issues of preference shares which were originally issued at different prices. There may be an original issue at a premium followed by a scrip issue at par, or vice versa. There may be an original issue at a premium followed by an issue of the same class in exchange for shares in another company, and such an issue is presumably deemed to be made at par. It is therefore extremely difficult, if not impossible, for a company to work the rules as they are at present.

A number of the arguments which I have adduced would attach in any case to all shares, but after an Act has been passed companies are deemed to know about it and to alter their plans in accordance with the new law. It is also possible to argue whether they know what the new law is. However, the Amendment refers only to shares issued before the crucial day in April, 1965, and issued with a contract on the part of the company that a premium would be paid on redemption. By these shares, a company becomes contractually liable to pay a premium and there can be no question of its altering its arrangements in accordance with the Act.

I ask the Chief Secretary to consider the Amendment very carefully and for this limited group of shares to treat the premium as a repayment of capital. Last year he was fairly sympathetic to a similar Amendment which related to the interest on bonus issues of debentures made before 6th April, 1965, and the grounds upon which he acceded to our request then was that there could have been no avoidance motive when the security was issued before last year's Budget. The same reasoning applies to this Amendment and we hope that the right hon. Gentleman will consider it very sympathetically.

Mr. Diamond

I consider everything the hon. Lady says very sympathetically. That is my privilege. Apparently, last year I went to the extremes of sympathy and accepted an Amendment—which, I regret to say, I have not reread—relating to debentures. The hon. Lady has been good enough to refresh my memory on that and to say that it was accepted then that there was no question of tax avoidance. Nobody suggests that tax avoidance enters the present argument.

There are two aspects to what the hon. Lady said, first the argument of substance and then the practical difficulties. This is not a question of tax avoidance, but simply a matter of whether a premium on share redemption is capital because it was regarded by the shareholder as an expectation of an addition to his capital. Everybody knows that a company provides for a premium on redemption of a share out of profits, except where it is provided out of a premium raised at the time of issue of the share, in which case that is put to a premium redemption account. That does not enter into this argument, because what is here being taxed is not the premium at redemption, but the difference between the premium at issue and the premium at redemption. Either that whole amount or part of it is provided out of profits.

Mrs. Thatcher

When an original issue price share is repaid out of profits as it can be, does that change the nature of the repayment from capital to income?

Mr. Diamond

I would not go the whole way with the hon. Lady about that. She has asked whether a different set of circumstances is analogous. That set of circumstances would require very careful consideration and I would probably not agree that it was in any way analogous, but that does not affect my perfectly accurate statement that the difference in the premium which is relevant for these purposes is provided out of profits.

Secondly, the way in which Corporation Tax moves is to say that anything which a shareholder gets out of the company, so long as the subscribed capital remains intact, is not a repayment of capital, but is a distribution—and the word "distribution" rather than "dividend", is used—and is a distribution of something other than capital. If it is not repayment of capital, it is distribution and it is therefore taxable in the ordinary way. I am bound to say that, for those solid reasons, I could not possibly recommend the House to accept the Amendment.

The hon. Lady went on to say that this would land me in certain practical difficulties and she regaled us with a long list of ways in which companies could make life complicated. The Revenue has not yet in practice had one of these diffi-

cult practical cases. That does not mean that we shall not have one, for we may. When we do, I think that no undue difficulty will be found in reaching agreement between Revenue and taxpayer about the way in which to deal with the matter sensibly and to apply the law sensibly to these rather difficult practical cases.

However, if in the administration of the law it is found that there are practical difficulties which cannot be resolved in the way which I have indicated, and which necessitate legislation, we shall produce legislation next year. In the meantime, we have no reason to believe that that will be necessary. Certainly, it is not necessary at the moment and certainly, for the good and solid reasons which I have given, I could not possibly recommend the House to accept the Amendment.

Mrs. Thatcher

By leave of the House, I cannot accept the right hon. Gentleman's argument that because a premium is sometimes paid out of profit, that necessarily changes the nature of the payment from capital to income payment. The premium may be repaid out of capital, in which case, on his argument, it should still have the quality of capital. There is, therefore, clearly a good deal of muddled thinking.

The Chief Secretary has not perhaps had as many practical problems yet because the Revenue is in any event very behind in some of its computations. I have no doubt that even more difficulties will arise in future than have arisen in the past. It will be better if we show our displeasure with the Chief Secretary's reply in the Division Lobby, and I would therefore advise my hon. and right hon. Friends, who seem to have been flooding into the Chamber in the last few moments, to divide the House.

Question put, That those words be there inserted in the Bill:—

The House divided: Ayes 152, Noes 213.

Division No. 399.] AYES [5.33 p.m.
Atkins, Humphrey (M't'n & M'd'n) Biggs-Davison, John Bromley-Davenport, Lt.-Col.Sir Walter
Awdry, Daniel Black, Sir Cyril Brown, Sir Edward (Bath)
Baker, W. H. K. Body, Richard Bruce-Gardyne, J.
Balniel, Lord Boyd-Carpenter, Rt. Hn. John Buchanan-Smith, Alick(Angus, N&M)
Bell, Ronald Braine, Bernard Bullus, Sir Eric
Bennett, Sir Frederic (Torquay) Brewis, John Carr, Rt. Hn. Robert
Cary, Sir Robert Hill, J. E. B. Page, Graham (Crosby)
Channon, H. P. G. Hirst, Geoffrey Pardoe, John
Ciegg, Walter Hogg, Rt. Hn. Quintin Peel, John
Cooke, Robert Holland, Philip Peyton, John
Cooper-Key, Sir Neill Hooson, Emlyn Pike, Miss Mervyn
Costain, A. P. Howell, David (Guildford) Pink, R. Bonner
Craddock, Sir Beresford (Spelthorne) Hunt, John Powell, Rt. Hn. J. Enoch
Crosthwaite-Eyre, Sir Oliver Hutchison, Michael Clark Prior, J. M. L.
Cunningham, Sir Knox Irvine, Bryant Godman (Rye) Pym, Francis
Currie, G. B. H. Jenkin, Patrick (Woodford) Ramsden, Rt. Hn. James
Dance, James Jennings, J. C. (Burton) Ridley, Hn. Nicholas
Davidson, James(Aberdeenshire, W.) Johnston, Russell (Inverness) Ridsdale, Julian
Dean, Paul (Somerset, N.) Kaberry, Sir Donald Rossi, Hugh (Hornsey)
Dodds-Parker, Douglas Kershaw, Anthony Royle, Anthony
Doughty, Charles King, Evelyn (Dorset, S.) Scott, Nicholas
Douglas-Home, Rt. Hn. Sir Alec Kirk, Peter Sharples, Richard
Elliott, R. W. (N'c'tle-upon-Tyne, N.) Kitson, Timothy Shaw, Michael (Sc'b'gh & Whitby)
Emery, Peter Lambton, Viscount Smith, John
Eyre, Reginald Langford-Holt, Sir John Steel, David (Roxburgh)
Farr, John Legge-Bourke, Sir Harry Stodart, Anthony
Fisher, Nigel Lloyd, Ian (P'tsm'th, Langstone) Stoddart-Scott, Col. Sir M. (Ripon)
Fletcher-Cooke, Charles Lloyd, Rt. Hn. Selwyn (Wirral) Tapsell, Peter
Fortescue, Tim Longden, Gilbert Taylor, Sir Charles (Eastbourne)
Foster, Sir John Lubbock, Eric Taylor, Edward M.(G'gow,Cathcart)
Galbraith, Hon. T. G. McAdden, Sir Stephen Taylor, Frank (Moss Side)
Gibson-Watt, David Macleod, Rt. Hn. Iain Temple, John M.
Gilmour, Ian (Norfolk, C.) McMaster, Stanley Thatcher, Mrs. Margaret
Gilmour, Sir John (Fife, E.) Maginnis, John E. Turton, Rt. Hn. R. H.
Glover, Sir Douglas Marples, Rt. Hn. Ernest van Straubenzee, W. R.
Goodhart, Philip Maude, Angus Wainwright, Richard (Colne Valley)
Gower, Raymond Mawby, Ray Walker-Smith, Rt. Hn. Sir Derek
Grant, Anthony Wall, Patrick
Grant-Ferris, R. Maxwell-Hyslop, R. J. Walters, Dennis
Gresham cooke, R. Maydon, Lt.-Cmdr. S. L. C. Ward, Dame Irene
Hall, John (Wycombe) Mills, Peter (Torrington) Webster, David
Hall-Davis, A. G. F. Mills, Stratton (Belfast, N.) Whitelaw, Rt. Hn. William
Hamilton, Michael (Salisbury) Mitchell, David (Basingstoke) Wills, Sir Gerald (Bridgwater)
Harris, Frederic (Croydon, N.W.) More, Jasper Wilson, Geoffrey (Truro)
Harris, Reader (Heston) Morrison, Charles (Devizes) Winstanley, Dr. M. P.
Harrison, Brian (Maldon) Munro-Lucas-Tooth, Sir Hugh Wolrige-Gordon, Patrick
Harrison, col. Sir Harwood (Eye) Murton, Oscar Worsley, Marcus
Harvey, Sir Arthur Vere Nicholls, Sir Harmar Younger, Hn. George
Harvie Anderson, Miss Noble, Rt. Hn. Michael
Health, Rt. Hn. Sir Lionel Onslow, Cranley TELLERS FOR THE AYES:
Heath, Rt. Hn. Edward Orr-Ew'mg, Sir Ian Mr. Bernard Weatherill and
Higgins, Terence L. Osborn, John (Hallam) Mr. Hector Monro.
Osborne, Sir Cyril (Louth)
Alldritt, Walter Crawshaw, Richard Forrester, John
Allen, Scholefield Crosland, Rt. Hn. Anthony Fowler, Gerry
Anderson, Donald Crossman, Rt. Hn. Richard Fraser, Rt. Hn. Tom (Hamilton)
Archer, Peter Dalyell, Tam Freeson, Reginald
Armstrong, Ernest Darling, Rt. Hn. George Galpern, Sir Myer
Atkins, Ronald (Preston, N.) Davies, Dr. Ernest (Stretford) Garrett, W. E.
Atkinson, Norman (Tottenham) Davies, G. Elfed (Rhondda, E.) Ginsburg, David
Bagier, Gordon A, T. Davies, Ifor (Gower) Greenwood, Rt. Hn. Anthony
Barnett, Joel Davies, S. O. (Merthyr) Gregory, Arnold
Baxter, William Delargy, Hugh Grey, Charles (Durham)
Beaney, Alan Dempsey, James Griffiths, David (Rother Valley)
Bence, Cyril Dewar, Donald Griffiths, Rt. Hn. James (Llanelly)
Bishop, E. S. Diamond, Rt. Hn. John Griffiths, Writ (Exchange)
Blackburn, F. Dickens, James Hamilton, James (Bothwell)
Blenkinsop, Arthur Dobson, Ray Hamilton, William (Fife, W.)
Boardman, H. Doig, Peter Hamling, William
Booth, Albert Dunn, James A. Hannan, William
Bowden, Rt. Hn. Herbert Dunnett, Jack Harper, Joseph
Braddock, Mrs. E. M. Dunwoody, Dr. John (F'th & C'b'e) Harrison, Walter (Wakefield)
Brooks, Edwin Eadle, Alex Haseldine, Norman
Brown, Rt. Hn. George (Belper) Edelman, Maurice Hattersley, Roy
Brown, Hugh D. (G'gow, Provan) Edwards, Rt. Hn. Ness (Caerphilly) Henig, Stanley
Brown, Bob(N'c'tle-upon-Tyne, W.) Edwards, Robert (Bilston) Herbison, Rt. Hn. Margaret
Brown, R. W. (Shoreditch & F'bury) Edwards, William (Merioneth) Horner, John
Buchan, Norman English, Michael Howarth, Harry (Wellingborough)
Buchanan, Richard (G'gow, Sp'burn) Ensor, David Howarth, Robert (Bolton, E.)
Butler, Herbert (Hackney, C.) Evans, Albert (Islington, S.W.) Howie, W.
Callaghan, Rt. Hn. James Evans, Ioan L. (Birm'h'm, Yardley) Huckfield, L.
Cant, R. B. Faulds, Andrew Hughes, Emrys (Ayrshire, S.)
Carmichael, Neil Fernyhough, E. Hughes, Hector (Aberdeen, N.)
Castle, Rt. Hn. Barbara Finch, Harold Hughes, Roy (Newport)
Chapman, Donald Fletcher, Ted (Darlington) Hunter, Adam
Coe, Denis Foot, Michael (Ebbw Vale) Jackson, Colin (B'h'se & Spenb'gh)
Coleman, Donald Ford, Ben Jackson, Peter M. (High Peak)
Concannon, J. D.
Janner, Sir Barnett Morris, Charles R. (Openshaw) Silkin, Rt. Hn. John (Deptford)
Johnson, James (K'ston-on-Hull, W.) Moyle, Roland Silkin, Hn. S. C. (Dulwich)
Jones, J. Idwal (Wrexham) Murray, Albert Silverman, Julius (Aston)
Kelley, Richard Neal, Harold Slater, Joseph
Kerr, Dr. David (W'worth, Central) Newens, Stan Small, William
Kerr, Russell (Feltham) Noel-Baker, Francis (Swindon) Spriggs, Leslie
Lawson, George Noel-Baker, Rt. Hn. Philip(Derby, S.) Steele, Thomas (Dunbartonshire, W.)
Lee, Rt. Hn. Frederick (Newton) Ogden, Eric Strauss, Rt. Hn. G. R.
Lestor, Miss Joan O'Malley, Brian Swain, Thomas
Lever, Harold (Cheetham) Oram, Albert E. Swingler, Stephen
Lewis, Arthur (W. Ham, N.) Oswald, Thomas Symonds, J. B.
Lewis, Ron (Carlisle) Owen, Dr. David (Plymouth, S'tn) Thomson, Rt. Hn. George
Lipton, Marcus Owen, Wilt (Morpeth) Tomney, Frank
Lomas, Kenneth Padley, Walter Tuck, Raphael
Loughlin, Charles Paget, R. T. Urwin, T. W.
Luard, Evan Palmer, Arthur Wainwright, Edwin (Dearne Valley)
Lyon, Alexander w. (York) Panned, Rt. Hn. Charles Walker, Harold (Doncaster)
Lyons, Edward (Bradford, E.) Park, Trevor Wallace, George
McCann, John Parkyn, Brian (Bedford) Watkins, David (Consett)
MacColl, James Pavitt, Laurence Watkine, Tudor (Brecon & Radnor)
MacDermot, Niall Pearson, Arthur (Pontypridd) Wellbeloved, James
Macdonald, A. H, Pentland, Norman Wells, William (Walsall, N.)
Mackenzie, Gregor (Rutherglen) Perry, Ernest C. (Battersea, S.) White, Mrs. Eirene
Mackie, John Price, William (Rugby) Whitlock, William
Mackintosh, John P. Probert, Arthur Willey, Rt. Hn. Frederick
McMillan, Tom (Glasgow, C.) Rankin, John Williams, Alan Lee (Hornchurch)
McNamara, J. Kevin Rees, Merlyn Williams, Clifford (Abertillery)
MacPherson, Malcolm Rhodes, Geoffrey Williams, Mrs. Shirley (Hitchin)
Mahon, Peter (Preston, S.) Richard, Ivor Williams, W. T. (Warrington)
Mallalieu, E. L. (Brigg) Roberts, Albert (Normanton) Willis, George (Edinburgh, E.)
Manuel, Archie Robertson, John (Paisley) Wilson, Rt. Hn. Harold (Huyton)
Mason, Roy Robinson, Rt. Hn. Kenneth (St.P'c'as) Wilson William (Coventry, S.)
Mayhew, Christopher Rogers, George (Kensington, N.) Woodburn, Rt. Hn. A.
Millan, Bruce Robinson, W. O. J. (Walth'stow, E.) Woof, Robert
Miller, Dr. M. S. Sheldon, Robert TELLERS FOR THE NOES:
Mitchell, R. C. (S'th'pton, Test) Shinwell, Rt. Hn. E. Mr. Alan Fitch and
Morgan, Elystan (Cardiganshire) Short, Rt. Hn. Edward (N'c'tle-u-Tyne) Mr. Neil McBride.
Morris, Alfred (Wythenshawe) Short, Mrs. Renée(W'hampton, N.E.)