§ '(1) The provisions of this section shall have effect for affording relief from tax under Case I or II of Schedule D where in a year of assessment ("the relevant year") the activities of a trade (which expression in this section includes a profession or vocation) are carried on by an individual partly outside the United Kingdom and the individual makes a claim for the relief.
§ (2) The relief shall be given by deducting from the profits of the trade in respect of which the individual is assessable to income tax for the relevant year (ascertained in accordance with sections 115 to 118 of the Taxes Act) the 918 foreign profits relief calculated in accordance with subsections (6) to (9) below.
§ (3) If the foreign profits relief exceeds the assessable profits for the relevant year the excess shall be carried forward to the next following year of assessment and deducted from the assessable profits of the trade for that year and so on to subsequent years as respects any excess still remaining until either the full foreign profits relief is given or the individual ceases to be engaged in the trade, but in no circumstances shall the foreign profits relief or any part of it be allowed more than once
§ (4) A claim for the foreign profits relief shall be made by notice in writing to the Inspector within two years of the end of the relevant year or within such further period as the Inspector may in the particular circumstances allow.919
§ (5) Payment in full of income tax in respect of the assessable profits of the trade for the relevant year (or any subsequent year to which the foreign profits relief or part of it might be carried forward under subsection (3) above) shall not be withheld or delayed because a claim for foreign profits relief may be made or has been made but not yet allowed, but on a claim being allowed such repayments of tax or other adjustments shall be made as are appropriate to give effect to the relief.
§ (6) The foreign profits relief shall, where subsection (8) below applies be equal to 100 per cent., and where subsection (9) below applies be equal to 25 per cent., of the foreign profits for the relevant year.
§ (7) For the purposes of subsection (6) above the foreign profits for the relevant year are the excess of the receipts of the trade property attributable to the activities of the trade personally carried on by the individual outside the United Kingdom in the relevant year over the deductible expenses of the trade properly attributable to those activities and in making the proper attribution all such apportionments of receipts and expenses referable partly to activities within and partly to activities outside the United Kingdom shall be made as are just in the circumstances.
§ (8) This subsection applies (so that the foreign profits relief is 100 per cent. of the foreign profits) if and to the extent that the foreign profits or part of them for the relevant year are attributable to activities of the trade carried on outside the United Kingdom during a qualifying period which falls wholly or partly in that year and consists of at least 365 days.
§ Sub-paragraphs (2) and (3) of paragraph 1 of Schedule 7 to this Act shall apply to determine what is a qualifying period for the purposes of this subsection.
§ (9) This subsection applies (so that the foreign profits relief is 25 per cent, of the foreign profits) to any foreign profits for the relevant year which are not within subsection (8) above, but only if in the relevant year the individual carries on activities of the trade outside the United Kingdom on at least 30 qualifying days.
§ For the purposes of this subsection a qualifying day is a day of absence from the United Kingdom which is substantially devoted to the activties of the trade (including travelling for the purposes of the trade).
§ (10) Paragraph 6 of Schedule 7 to this Act shall apply for the purposes of subsections (8) and (9) above.
§ (11) Where the trade is carried on by the individual in partnership the foreign profits relief shall be allowed against his share of the assessable profits of the trade for the relevant year (or of any subsequent year to which the relief is carried forward under subsection (3) above), but not so as to prevent the partners allocating the benefit of the relief between themselves in whatever way they agree.
§ (12) This section has effect for 1977–78 and subsequent years of assessment."—[Sir G. Howe.]
§ Brought up, and read the First time.920
§ New Clause 8—Expenses in connection with trade, etc., carried on wholly abroad.
§ New Clause 66—Separate assessment for work abroad.
§ Sir G. Howe
The House, which has not had the pleasure of following the sometimes less than exhilarating proceedings in Standing Committee, will want to know why the clause has been tabled and what it is about. I shall relate the basic history.
From 1974 the Government altered the basis of taxation of overseas earnings, required them to be remitted to this country and placed them on a full taxation basis. That has given rise to increasing anxiety and concern. Many people, whether employed or self-employed, have found themselves paying intolerably high levels of taxation on earnings made overseas. The Government have been driven by the facts of life and the advocacy of my hon. Friend's into altering the law so as to make some exceptions and concessions with the intention of reducing the tax rates payable on a proportion of earnings from overseas in certain conditions.
The clauses giving effect to that are now in the Bill. Clause 31 provides some relief for expenses incurred on earnings overseas. Clause 30 provides basically that if an employee is overseas for 365 days, there is total relief on the earnings during that period. If he is overseas for more than 30 days, defined with some Byzantine complexity, there is relief on 25 per cent. of the earnings overseas in that period.
Those provisions are for the benefit of employees, but there are no comparable provisions for the earnings overseas of self-employed people—those who are working in any trade, profession or vocation, whether as individuals or as partners. The Government propose to continue the regime whereby the overseas earnings of self-employed people continue to be subject to the full discipline and rigour of the tax code designed by the Chief Secretary and his colleagues. Anyone on being told about this must stand back with astonishment and say "If they have recognised the case for providing licensed 921 loopholes from our dreadful tax system for employed people, why is it that they have not been able to do the same for self-employed people?" The answer is astonishing to anyone who has any concept of equity, simpicity or intelligibility about the tax system. It is "We are frightfully sorry, but we cannot design a system to help these people."
We cannot fail to notice that, as so often with this Government, the victims of their inertia or incompetence are the self-employed. On so many fronts, advertently or inadvertently, maliciously or otherwise, this Government have maintained or created additional burdens, traps and hazards for the self-employed so that those who fall into this category believe themselves to be the victims of a sustained war and vendetta.
Seeing the Chief Secretary sitting benignly on the Treasury Bench it is hard to believe that he is steering a campaign of this kind. It may not be many weeks before he finds himself back in this situation—self-employed, seeking to scavenge such earnings as he can from any corner of the world where he can secure employment. One would have thought that self-interest would drive him in a sensible direction. It is intolerable to have a tax system which has such harsh edges about it that even this Government recognise that they have to abate them, and then to find that they say blandly "We are sorry, but we have not been able to work it out."
We are not, after all, talking about self-employed barrow boys plying their trade up and down Oxford Street with no consequence to the economy. We are talking about people with highly professional skills—consulting engineers, accountants, architects and people with skills of that kind. They earn very substantial quantities of invisible earnings outside this country and, what is more, frequently they provide the foundation for larger contracting exercises and larger areas of employment for Britons overseas. They are the seeds of Britain's overseas trade. They help to pull back to this country substantial earnings. They make a major contribution to the health of the economy. There can be no justification for not seeking to remedy their position.
922 If one looks, as I have rather sadly, at the debates in Committee, one sees that my hon. and learned Friend the Member for Dover and Deal (Mr. Rees) said, with that formidable authority that he can always command, that the case he was making was "virtually unanswerable." My only sense of surprise was that he included the word "virtually". It was a modest and uncharacteristic qualification. The case is unanswerable.
In the face of the arguments of the Opposition, the Chief Secretary, on the face of it, was in a forthcoming mood. He said:I join with all hon. Gentlemen who have spoken in wanting to see relief given both to the self-employed and special people as well as to employees. I want to explain some of the problems and then show how the amendments and new clauses, which have attempted very assiduously to deal with the problems so as to avoid some of the consequences that could befall an over-simplified scheme of relief, do not meet the situation going on to say how I hope that eventually we shall be able to do so."—[Official Report, Standing Committee D, 15th June 1977; c. 646.]Then the right hon. Gentleman went into an argument, which I find unconvincing, that it was very difficult to define —that it was impossible to define the amount of overseas earnings made in the circumstances and that it was impossible to define the period in which the earnings were made so as to fulfil the formula set out in the Opposition's new clause I find that wholly unconvincing.
Perhaps I might weary the House for a moment with my own experience in a somewhat different role. When I used to ply my trade as a barrister on the Wales and Chester circuit, which, from chambers in London, might be regarded as earning one's living "overseas", I had to satisfy the Inland Revenue, as part of the purpose of the tax regime at that time, that I was spending two nights in Chester, one in Caernarvon and one in Dolgelly, claiming legitimate expenses. I had to keep records of the fee that I received in Caernarvon or in Haverfordwest. It was not difficult. I had to say that my earnings from the circuit were£X, my expenses were£Y and my total income was therefore£X minus Y. The problem was no more complicated than that. We are not convinced that it is beyond the ability of the Treasury to solve this problem.
923 The Chief Secretary closed his speech in Standing Committee by saying:What I can say is that the Government, for their part, and certainly I for my part, will continue the search for a way to bring sole traders, professional people and partnerships into the relief. I cannot promise to be able to do that in time for Report, but I expect to be able to have the relief provision ready in time for the next Finance Bill.— [Official Report, Starding Committee D; 15th June 1977; c. 651–2.]That is simply not good enough. It is three years since the right hon. Member designed the régime from which he is now seeking to escape. It is nine months since a consultative document was produced to help those people who are employed. I cannot believe that it is beyond the capacity of a Government who have any real feeling for the self-employed to give relief in that area. If the Chief Secretary repeats what he said in Standing Committee—that he expects to introduce relief in time for the next Finance Bill—we shall ask why he has not got it ready in time for this one. I hope that the Chief Secretary will be full of enthusiastic repentance and will be ready to accept this new clause, which makes an unanswerable case.
§ Mr. Ridley
I support what my right hon. and learned Friend the Member for Surrey, East (Sir G. Howe) has said. The burden of the Chief Secretary's case upstairs was that it was far too complicated to work out the base period from which overseas earnings of the self-employed would derive, or indeed to assess what those earnings were.
I intervened in that speech by the right lion. Gentleman and cited the case of a life insurance salesman who might make considerable sums in commission although he was employed. The Chief Secretary said:I agree that there are problems, but the extent of the problem generally—and this is the point that I am trying to make—in the case of Schedule D is much greater than in the case of Schedule E."—[Official Report, Standing Committee D, 15th June 1977; c. 650.]I dispute that. Suppose that a salesman selling an expensive piece of capital equipment is employed by a big manufacturing firm, which arranged things so that instead of paying a salary to its salesmen it paid very large commissions on each sale. In this case, all that a salesman has to do is to stay 30 days and 924 have a rest in the delightful surroundings of Kuwait or Qatar and he qualifies for 25 per cent. relief just because he has made the sale. It seems just as easy to get round it if one is employed and to maximise one's foreign earnings as it is if one is self-employed.
Take our newest export phenomenon —Sidi Ben Revie—who is being paid£300,000 a year tax-free to teach the United Arab Emirates how to play football. That is a most purposeful export. That is the sharp end of exporting which should attract the Duke of Edinburgh's award, and we are delighted. But suppose that he gets fed up with the heat, the sand and the conditions and comes back to England in a year. The Chief Secretary will be after him, the Revenue hounds will be on to him and the question will be raised of whether he was self-employed or employed out there. I suspect that he will prove that he was self-employed. If, however, it is proved that he was employed, it will make a considerable difference to the amount of tax he has to pay. That cannot be right. The complications, whether one is employed or self-employed, are equal and real.
I am not convinced that we should have this relief for the employed. I have every sympathy for the man who works in the heat and sweat of the foundry—perhaps more sympathy for him than for the man who goes to Monaco to sell the product during a gentle weekend in the sun—but I do not accept the basic premise.
Be that as it may, if we are prepared to give this relief at all, the complications are equal all round. To do it for the employed only enhances the unfortunate reputation that the Government have for bias against the self-employed. I should have thought that in the interests of their own public relations and their tentative and tendentious appeal to the self-employed —
§ Mr. Ridley
My right hon. and learned Friend suggests that the Government have given up caring about the self-employed. Is it that no insult or injury to the self-employed matters to them any more, because they reckon that they are not 925 likely to be attracted to them in the polls? If so, it is a shocking state of affairs.
If the Chief Secretary cannot design relief for the self-employed at the same time as he brings in relief for the employed, I suggest that it is better to scrap the whole thing and to bring it in again in another year on a fairer basis. It is the inequity of the situation that is offensive. It follows a whole history of other actions against the self-employed that will not lightly be forgotten.
We are dealing with people who are not tax evaders or whelk stall operators. We are dealing with important firms of consulting engineers, technical experts, accountants, lawyers and so on. They are probably doing more for our exports than many of our manufacturing companies. I find the discrimination nauseous. As the Chief Secretary appears to be of the same—[Interruption.] The hon. Member for Liverpool, Walton (Mr. Heffer) could not run a whelk stall from a seated position.
§ Mr. Heffer
The hon. Member for Cirencester and Tewkesbury (Mr. Ridley) could not run anything from any position.
§ Mr. Ridley
Having run a contracting company for 10 years, I would not take on the hon. Gentleman, employed or self-employed.
§ Mr. Ridley
I am seeking to keep in order under considerable provocation. I really have nothing more to say. The hon. Member for Walton succeeded in destroying my peroration, for which I give him full credit.
§ Mr. Ridsdale
I support the new clause.
I wonder whether this will be the first of many such clauses and exemptions. In order to stop abuse, the Government have got themselves into very difficult water. I am sure that they want to help those who help our invisible exports.
926 Our invisible exports provide half of what our manufacturing exports are achieving. For the Government to treat people who try to earn their living abroad in this way is a very poor effort indeed.
I suggest to the Government that the one way to get round it and to help not only the self-employed but others is to see whether the earnings genuinely arise and then these people can be helped. Unless that is done, we shall have exemption after exemption and we shall not help those who are earning invisible wealth for this country. I ask the Government to consider the word "genuine". We should go back to the position that existed in 1974 and consider genuine earnings arising abroad.
§ Mr. Joel Barnett
If I were being my customary polite self, I should say what interesting speeches we have heard. However, I am bound to say that the speeches of the right hon. and learned Member for Surrey, East (Sir G. Howe) and of the hon. Member for Cirencester and Tewkesbury (Mr. Ridley) were somewhat naive. The right hon. and learned Gentleman gave a somewhat superficial description of the situation. The right hon. and learned Gentleman knows why we have the clause giving relief for employees and he should know why it is not possible to give relief to the self-employed as well at this stage.
The right hon. and learned Gentleman knows that this goes back to the days of the remittance basis that the right hon. Member for Sidcup (Mr. Heath) described so graphically when he spoke of the unacceptable face of capitalism. It derives precisely from that. The right hon. and learned Gentleman knows better than that, and if he does not, he should.
§ Mr. Barnett
That is exactly what I am doing and I am trying to put things into the right perspective. The right hon. and learned Member for Surrey, East should not sit there mumbling, because he knows that it is true. It stems from the abuse of the remittance basis on a large scale.
We had a choice. We could have simply abolished the remittance basis and put 927 nothing in its place and given no relief whatsoever. However, we decided that we wanted to give some relief to those who spend some time abroad doing a first-class job for this country. In this instance we did it by giving relief for employees who spend 30 days a year abroad. We did that after consultation with all those involved. This is the best way to deal with the matter.
I readily accept that in giving relief there arc anomalies. There is no way to avoid anomalies in dealing with such relief. When the right hon. and learned Member for Surrey. East talks about the victims among the self-employed and says that we are not dealing with barrow boys he must know that he is talking the utmost rubbish. We are talking about the difference between Schedule D and Schedule E.
An interesting thing about the next new clause that we shall debate is that the Opposition will then be seeking to get people off Schedule E and on to Schedule D because it will be much better for them to be assessed as self-employed. The hon. Member for Blaby (Mr. Lawson) is muttering now. I know that he is not used to being criticised and I do not intend to do that. However, he does not like it when I tell him the truth about the background of the matter. The remittance basis from which it stems was abused, and in the tax system we have sought to deal with this in a reasonable and fair way.
The right hon. and learned Gentleman said that he and his hon. Friends believed that there was little difference between Schedule D and Schedule E. Do they really believe that? The right hon. and learned Gentleman is aware that the Schedule E is an actual basis assessment whereas Schedule D is based on the preceding year—but not always. The matter is somewhat complicated. Expenses are calculated in one year and profits in another. The whole thing is extremely complicated and I do not apologise for that.
§ Mr. Barnett
Let the hon. and learned Member for Solihull (Mr. Grieve) intervene when he is more rational. He knows that there is a considerable difference 928 between the Schedule D and the Schedule E basis.
I said in Committee that I recognise the need to do something about the problem. but it is not possible without giving opportunities for abuse, to exempt in a simple piece of legislation the self-employed under Schedule D who are working abroad for 30 days in the year. We have to devise legislation that will be somewhat complex and that will take time if we are to avoid the sort of abuses that even hon. Members opposite would not want to see—though maybe I should withdraw that statement. Most hon. Members would not wish to see the sort of abuses that would be possible if we drafted loose legislation.
Most people recognise that we have gone a long way towards helping. Certainly that is the view of those we consulted in drafting the legislation. Naturally, they would have liked us to include in the legislation this year something for the self-employed—the professional men we are talking about. We shall do that in next year's Finance Bill. The Labour Government will have many more Finance Bills to introduce and in next year's we shall deal with the problem while avoiding the abuses that would be inherent if we accepted the new clause.
§ Mr. Peter Rees
I would not have intervened in this debate, since I spoke at certain length in Committee, but for the incredible reply of the Chief Secretary to this important new clause. He has sunk below the standards of punctilio and care that he shows from time to time.
The hon. Member for Liverpool, Walton (Mr. Helfer) is saying something from a sedentary position. I can assure him that my hands are roughened from unremunerated manual toil as last weekend I was cutting down a few trees—in the manner of Gladstone. I say that to demonstrate my credentials for intervening.
I also declare a personal interest as a professional person who occasionally swells this country's export receipts by professional representation in courts outside this country. The hon. Member for Walton seems to he encouraging me to go further away from this country. I must leave that to my electorate and the hon. Gentleman's future to his electorate.
929 The new clause was canvassed upstairs. The Chief Secretary has sought to appeal to emotion by reference to the remittance basis with its echoes of the face of capitalism, whether ugly, unacceptable, attractive or appealing, that we scrutinised with some care when examining the affairs of Lonrho. Since we are in an emotional area, I remind the House that right hon. and hon. Members have been quite ready to profit from capitalism. I know that some right hon. Gentlemen opposite have not thought it dishonourable to take paid appointments with multinational companies based in Liberia. I hope very much that the hon. Gentleman will realise that even he has a future under the capitalist system. Quite what it is I shall have to explore with him outside the Chamber.
There have been other right hon. Gentlemen opposite who have cared to try their fortunes in the banking world, I am sure to the mutual profit of the banks that have employed them and themselves. I find this neither discreditable nor unreasonable. We live in a mixed economy, and I should much prefer that they hazard their skills and their labour, such as they are, in the private sector rather than that they should be carried as parasites on the public payroll in some nationalised industry.
The hon. Gentleman indicates that he wishes to be carried on the private payroll, or does he prefer the softer, more opulent terms of the public payroll? To his credit, he forswore the public payroll. Perhaps I should not remind him of that short unhappy interlude in his career, but as he is barracking me from a sitting position and as I know him to be a man of robust resilience, I know that he is not ashamed to bandy words with me, and I am not ashamed to bandy words with him.
Just to get the record straight, let me tell the hon. and learned Gentleman that my dealings with the banks seem to be profitable from their point of view. I borrow a few bob at a high rate of interest. The banks have done well out of me.
§ Mr. Rees
I am glad to hear that the hon. Gentleman is so creditworthy. It is not for me to probe into his affairs. There is a great future for him on the Mersey 930 Docks and Harbour Board and other institutions of that kind. Whether that is compatible with his position in this House is perhaps a matter on which I might seek Mr. Speaker's ruling on another occasion.
I leave the hot lush pastures of Liberia and the slightly cooler, if more moist, pastures of Cardiff and come back to the new clause. With characteristic self-restraint, I was disposed to say in Standing Committee that perhaps the case was virtually unanswerable for putting the self-employed on a level with directors and I picked companies at length such as Diebold Inc. or the Hodge Group—great respectable pillars of the capitalist system.
I happen to be a threadbare professional man.
§ Mr. Rees
It is not for me to explore every recess of the capitalist system that has from time to time housed a denizen of the Government Front Bench, whether in this House or another place. Perhaps you, Mr. Speaker, in your infinite mercy and wisdom will find time for us to explore the situation of that company and those who at some time graced its board.
I have declared by personal interest. I have declared what modest contribution I have made to the invisible exports of this country. I hope that I shall find myself shoulder to shoulder with the Chief Secretary in our endeavours quite soon because he, too, will no doubt be bending his considerable talents to assist the professional classes of this country both inside and outside the country.
The purpose of this clause, which follows closely the clause that we debated at some length in Standing Committee, is concerned with all the various aspects of the export drive and how the Prime Minister with his well-known verve and enthusiasm could give us extra impetus and push. We come back to the same matter, and once again, apart from a singularly unfortunate lapse, which I am sure he is regretting, in his rather unsolicitous reference to the Lonrho Company, the Chief Secretary has advanced precisely the same argument and told us that the practical difficulties are too great and 931 that they defy even his and the Financial Secretary's agile minds.
In the weeks between the Committee stage and Report the right hon. Gentleman, assisted by the vast resources of Somerset House, has been unable to devise a clause that will meet the aspirations that apparently both sides of the House cherish. Even the hon. Member for Walton apparently wishes to assist the self-employed. That is good news. I was beside him in debates on devolution and other constitutional issues, and it is good to know that we speak as one on the self-employed.
§ 10.15 p.m.
§ Mr. Rees
The hon. Gentleman is censorious of those who spread themselves in our debates, but he was not above exploiting our procedure to the maximum to achieve some sn-all constituency aim. Whether he was successful I am no longer aware, but he caused grief to the Patronage Secretary. I ask him to bear with me as I bore with him—
§ Mr. Speaker
Order. All those activities took place entirely at home, and what we are discussing relates partly to activities abroad. We really must get back to it.
§ Mr. Rees
But for ill-timed interventions, I should have been on the new clause. The Chief Secretary has rested his case on practical difficulties, yet he and the Financial Secretary have had since the summer of 1974 to consider these problems. Between September and October 1974, with a burst of unaccustomed energy and acumen, the Chief Secretary constructed a whole new system of taxing capital—capital transfer tax. He is a man of great industry and ingenuity, so why has he not been able to deal a little more generously with the self-employed in the period since 1974? For all his fine words, he is dragging his feet.
932 It is not enough for the right hon. Gentleman to console us by saying that he will introduce another Finance Bill next year. We doubt it, and the problem is more pressing than that. The self-employed have suffered under his whiplash for too long. Had he applied himself, he could have produced something, since 1974 if not since the Committee stage.
We appreciate that those assessed on Schedule E are assessed on a current year basis while those assessed under Case 1 and Case 2 of Schedule D are assessed on a preceding year basis—although not always. What insuperable problems does that create? The right hon. Gentleman has not shown his customary assiduity. Indeed, the Official Box has been thinning out during this debate, which suggests that he has not mobilised all the resources of Somerset House.
I hope that we shall not he satisfied with these fair words and idle promises. The problem is immediate and deserves an immediate response. I hope, therefore, that my right hon. and learned Friend, recalling the fine times that he and I spent in various forts west of Offa's Dyke, will lead us into the Lobby unless we receive a far more concrete assurance than we have so far had.
§ Sir G. Howe
I need no more encouragement than that given by my hon. and learned Friend the Member for Dover and Deal (Mr. Rees) to say that the Chief Secretary's answer is unsatisfactory. He has given no reason for not providing solutions to this problem along the lines in the new clause.
The only thing that grieved us was the uncharacteristic intemperance with which the right hon. Gentleman denounced our arguments. It suggested that he had no confidence in his own case. One wonders whether he might not have been upset in recent days, having sweated his guts out writing draft after draft of the long-heralded White Paper only to see it torn to shreds by his colleagues in the Cabinet. However, it is not for us to speculate. There must be some curious reason for him to be less than his usual equable self. We shall deal with him in the same way as we have done so often in the past—by voting in favour of the clause and against him.
§ Question put, That the clause be read a Second time:—934
§ The House divided: Ayes 182, Noes 226.935
|Division No. 198.]||AYES||[10.20 p.m.|
|Adley, Robert||Grist, Ian||Osborn, John|
|Aitken. Jonathan||Hamilton, Michael (Salisbury)||Page, John (Harrow West)|
|Alison, Michael||Hampson, Dr Keith||Page, Rt Hon R. Graham (Crosby)|
|Atkins, Rt Hon H. (Spelthorne)||Hannam, John||Page, Richard (Wcrkington)|
|Awdry, Daniel||Haselhurst, Alan||Pattie, Geoffrey|
|Bain, Mrs Margaret||Havers, Rt Hon Sir Michael||Price, David (Eastleigh)|
|Baker, Kenneth||Hawkins, Paul||Raison, Timothy|
|Banks, Robert||Hayhoe, Barney||Rathbone, Tim|
|Bell, Ronald||Henderson, Douglas||Rawlinson, Rt Hon Sir Peter|
|Berry, Hon Anthony||Hicks, Robert||Rees, Peter (Dover & Deal)|
|Biffen, John||Higgins, Terence L.||Reid, George|
|Blaker, Peter||Hodgson, Robin||Rhodes James, R.|
|Boscawen, Kon Robert||Howe, Rt Hon Sir Geoffrey||Rhys Williams, Sir Brandon|
|Bottomley, Peter||Howell, David (Gulldlord)||Ridley, Hon Nicholas|
|Boyson, Dr Rhodes (Brent)||Howell. Ralph (North Norfolk)||Ridsdaie, Julian|
|Braine, Sir Bernard||Hunt, David (Wirral)||Rifkind, Malcolm|
|Brocklebank-Fowler, C.||Hurd, Douglas||Roberts, Michael (Cardiff NW)|
|Brooke, Peter||Hutchison, Michael Clark||Roberts, Wyn (Conway)|
|Brotherton, Michael||James, David||Rossi, Hugh (Hornsey)|
|Brown, Sir Edward (Bath)||Jessel, Toby||Royle, Sir Anthony|
|Buchanan-Smith, Alick||Johnson Smith, G. (E Grinstead)||Sainsbury, Tim|
|Buck, Antony||Keilett-Bowman, Mrs Elaine||Scott, Nicholas|
|Budgen, Nick||Kimbali. Marcus||Shaw, Giles (Pudsey)|
|Burden, F. A.||King, Evelyn (South Dorset)||Shaw, Michael (Scarborough)|
|Butler. Adam (Bosworth)||King, Tom (Bridgwater)||Shelton, William (Streatham)|
|Chalker, Mrs Lynda||Knox, David||Shepherd, Colin|
|Channon, Paul||Lamont, Norman||Silvester, Fred|
|Churchill, W. S.||Lawson, Nigel||Smith, Dudley (Warwick)|
|Clark, Alan (Plymouth, Sutton)||Le Merchant, Spencer||Smith, Timothy John (Ashfield)|
|Clark, William (Croydon S)||Lester, Jim (Beeston)||Spence, John|
|Clarke, Kenneth (Rushclltfe)||Lewis, Kenneth (Rutland)||Spicer, Jim (W Dorset)|
|Clegg, Walter||Lloyd, Ian||Spicer, Michael (S Worcester)|
|Cockcrott, John||Loveridge, John||Sproat, lain|
|Cooke, Robert (Bristol W)||McCrindle, Robert||Stanley, John|
|Costain, A. P.||Macfarlane, Neil||Stewart, Ian (Hitchin)|
|Critchley, Julian||MacGregor, John||Stokes, John|
|Dean, Paul (N Somerset)||Macmillan, Rt Hon M. (Farnham)||Stradling Thomas, J.|
|Dodsworth, Geoffrey||McNair-Wilson, M. (Newbury)||Tapsell, Peter|
|du Cann, Rt Hon Edward||McNair-Wilson, P. (New Forest)||Taylor, R. (Croydon NW)|
|Dykes, Hugh||Madel, David||Tebbit, Norman|
|Elliott, Sir William||Marten, Neil||Thatcher, Rt Hon Margaret|
|Emery. Peter||Mather, Carol||Thomas, Rt Hon P. (Hendon S)|
|Farr, John||Maude, Angus||Thompson, George|
|Fell, Anthony||Maxwell-Hyslop, Robin||Townsend, Cyril D.|
|Fisher, Sir Nigel||Meyer, Sir Anthony||Trotter, Neville|
|Fletcher, Alex (Edinburgh, N)||Miller, Hal (Bromsgrove)||van Straubenzee, W. R.|
|Fookes, Miss Janet||Mills, Peter||Viggers, Peter|
|Forman, Nigel||Miscampbell, Norman||Wakeham, John|
|Fowler, Norman (Sullon C'f'd)||Moate, Roger||Walder, David (Clitheroe)|
|Fox, Marcus||Moore, John (Croydon C)||Walker, Rt Hon P. (Worcester)|
|Fry, Peter||More, Jasper (Ludlow)||Walker-Smith, Rt Hon Sir Derek|
|Gardner, Edward (S. Fylde)||Morgan, Geraint||Wall, Patrick|
|Gllmour, Rt Hon Sir Ian (Chesham)||Morgan-Giles, Rear-Admiral||Walters, Dennis|
|Gilmour, Sir John (East File)||Morris, Michael (Northampton S)||Warren, Kenneth|
|Glyn, Dr Alan||Morrison, Charles (Devizes)||Weatherill, Bernard|
|Godber, Rt Hon Joseph||Mudd, David||Wiggin, Jerry|
|Goodhew, Victor||Neave, Airey||Wigley, Dafydd|
|Gow, Ian (Eastbourne)||Neubert, Michael||Young, Sir G. (Eating, Acton)|
|Gower, Sir Raymond (Barry)||Newton, Tony|
|Grant, Anthony (Harrow C)||Normanton, Tom||TELLERS FOR THE AYES:|
|Gray, Hamish||Onslow, Cranley||Lord James Douglas-Hamilton and|
|Grieve, Percy||Oppenheim, Mrs Sally||Mr. Peter Morrison.|
|Anderson, Donald||Boardman, H.||Cartwrlght, John|
|Archer, Rt Hon Peter||Booth, Rt Hon Albert||Castle, Rt Hon. Barbara|
|Atkins, Ronald (Preston N)||Bradley, Tom||Clemitson, Ivor|
|Bagier, Gordon A. T.||Bray, Dr Jeremy||Cocks, Rt Hon Michael|
|Barnelt, Guy (Greenwich)||Brown, Hugh D. (Provan)||Cohen, Stanley|
|Barnett, Rt Hon Joel (Heywood)||Brown, Ronald (Hackney S)||Coleman, Donald|
|Bates, Alf||Buchan, Norman||Cook, Robin F. (Edln C)|
|Bean, R. E.||Callaghan, Rt Hon J. (Cardiff SE)||Corbett, Robin|
|Benn, Rt Hon Anthony (Wedgwood)||Callaghan, Jim (Middleton & P)||Cowans, Harry|
|Bennett, Andrew (Stockport N)||Campbell, Ian||Crawshaw, Richard|
|Bldwell, Sydney||Canavan, Dennis||Cronin, John|
|Bishop, Rt Hon Edward||Cant, R. B.||Crowther, Stan (Rotheiham)|
|Blenkinsop, Arthur||Carter-Jones, Lewis||Cryer, Bob|
|Cunningham, G. (Islington S)||Jeger, Mrs Lena||Price, William (Rugby)|
|Cunningham, Dr J. (Whiter)||Jenkins, Hugh (Putney)||Roberts, Albert (Normanton)|
|Dalyell, Tam||John, Brynmor||Roberts, Gwilym (Cannock)|
|Davies, Bryan (Enfield N)||Johnson, James (Hull West)||Robinson, Geoffrey|
|Davles, Denzil (Llanelll)||Johnson, Walter (Derby S)||Roderick, Caerwyn|
|Davies, Ifor (Gower)||Jones, Alec (Rhondda)||Rodgers, George (Chorley)|
|Davis, Clinton (Hackney C)||Jones, Dan (Burnley)||Rooker, J. W.|
|Deaklns, Eric||Judd, Frank||Rose, Paul B.|
|Dean, Joseph (Leeds West)||Kelley, Richard||Ross, Stephen (Isle of Wight)|
|de Freitas, Rt Hon Sir Geoffrey||Kerr, Russell||Rowlands, Ted|
|Dell, Rt Hon Edmund||Kilroy-Silk, Robert||Sedgemore, Brian|
|Dormand, J. D.||Kinnock, Neil||Selby, Harry|
|Douglas-Mann, Bruce||Lamborn, Harry||Shaw, Arnold (Ilford South)|
|Dunnett, Jack||Lamond, James||Sheldon, Rt Hon Robert|
|Eadle, Alex||Lee, John||Shore, Fit Hon Peter|
|Edge, Geoff||Lestor, Miss Joan (Eton & Slough)||Silkin, Rt Hon John (Deptford)|
|Edwards, Robert (Wolv SE)||Lever, Rt Hon Harold||Silkin, Rt Hon S. C. (Dulwich)|
|Ellis, John (Brigg & Scud)||Lomas, Kenneth||Sillars, James|
|Ellis, Tom (Wrexham)||Luard, Evan||Silverman, Julius|
|English, Michael||Lyon, Alexander (York)||Skinner, Dennis|
|Evans, Fred (Caerphilly)||Lyons, Edward (Bradford W)||Smilh, John (N Lanarkshire)|
|Evans, loan (Aberdare)||McCartney, Hugh||Snape, Peter|
|Evans, John (Newton)||McDonald, Dr Oonagh||Spearing, Nigel|
|Ewlng, Harry (Stirling)||McElhone, Frank||Spriggs, Leslie|
|Fernyhough, Rt Hon E.||McGuire, Michael (Ince)||Stallard, A. W.|
|Fletcher, Ted (Darlington)||MacKenzie, Rt Hon Gregor||Steel, Rt Hon David|
|Foot, Rt Hon Michael||Maclennan, Robert||Stewart, Rt Hon M. (Fulham)|
|Ford, Ben||McNamara, Kevin||Stoddart, David|
|Forrester, John||Madden, Max||Stott, Roger|
|Fraser, John (Lambeth, N'w'd)||Magee, Bryan||Strang, Gavin|
|Freeson, Reginald||Mahon, Simon||Strauss, Rt Hon G. R.|
|Freud, Clement||Mallalieu, J. P. W.||Swain, Thomas|
|Garrett, John (Norwich S)||Marshall, Jim (Leicester S)||Taylor, Mrs Ann (Bolton W)|
|Garrett, W. E. (Wallsend)||Maynard, Miss Joan||Thomas, Jeffrey (Absrtillery)|
|George, Bruce||Meacher, Michael||Thomas, Mike (Newcastle E)|
|Ginsburg, David||Melllsh, Rt Hon Robert||Thomas, Ron (Bristol NW)|
|Gofdlng, John||Mitchell, R. C. (Soton, Itchen)||Tierney, Sydney|
|Gourlay, Harry||Molloy, William||Tomlinson, John|
|Graham, Ted||Moonman, Eric||Torney, Tom|
|Grant, George (Morpeth)||Morris, Alfred (Wythenshawe)||Urwin, T. W.|
|Grant, John (Islington C)||Morris, Rt Hon J. (Aberavon)||Varley, Rt Hon Eric G.|
|Grimond, Rt Hon J.||Moyle, Roland||Wainwright, Edwin (Dearne V)|
|Grocott, Bruce||Melley, Rt Hon Frederick||Wainwright, Richard (Colne V)|
|Hamilton, James (Bothwell)||Murray, Rt Hon Ronald King||Ward, Michael|
|Hardy, Peter||Newens, Stanley||Weetch, Ken|
|Harper, Joseph||Noble, Mike||Wellbeloved, James|
|Harrison, Rt Hon Walter||Oakes, Gordon||White, Frank R. (Bury)|
|Hattersley, Rt Hon Roy||Ogden, Eric||White, James (Potlok)|
|Hatton, Frank||O'Halloran, Michael||Whitehead, Phillip|
|Hayman, Mrs Helene||Orbach, Maurice||Willey, Rl Hon Frederick|
|Healey, Rt Hon Denis Heffer, Eric S.||Orme, Rt Hon Stanley Ovenden, John||Williams, Rt Hon Alan (Swansea W)|
|Hooiey, Frank||Owen, Rt Hon Dr David||Williams, Sir Thomas (Warrington)|
|Hooson, Emlyn||Padley, Walter||Wilson, Rt Hon Sir Harold (Huyton)|
|Howell, Rt Hon Denis (B'ham, Sm H)||Palmer, Arthur||Wilson, William (Coventry SE)|
|Howells, Geralnt (Cardigan)||Pardoe, John||Wise, Mrs Audrey|
|Hoyle, Doug (Nelson)||Park, George||Woodall, Alec|
|Huckfleld, Les||Parry, Robert||wool, Robert|
|Hughes, Robert (Aberdeen M)||Pavitt, Laurie||Young, David (Bolton E)|
|Hughes, Roy (Newport)||Pendry, Tom|
|Hunter, Adam||Penhallgon, Davlo||TELLERS FOR THF NOES|
|Jackson, Colin (Brighouse)||Perry, Ernest||Mr. Thomas Cox and|
|Jackson, Miss Margaret (Lincoln)||Prescott, John||Mr. Joseph Ashton.|
|Janner, Greville||Price, C. (Lewisham W)|
|Question, accordingly negatived.|