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Dáil Éireann debate -
Wednesday, 11 Jun 1930

Vol. 35 No. 7

International Conventions. - Finance Bill, 1930—Report.

I move amendment 1:—

1. In page 7, section 17 (1), line 62, to delete the word "issue" and substitute the word "acquisition."

The object of the amendment is slightly to extend the range of investments which might be purchased. If we could only purchase investments maturing twelve months from the date of issue it would be confined to Treasury Bills, whereas with the amendment it would be possible to purchase certain shortdated Treasury and Exchequer Bonds which would yield a much higher rate of interest.

Amendment agreed to.

I move amendment 2:—

In page 8, section 19 (1), to delete all words from the word "Where," line 24, to and including the word "account," line 33, and substitute the words—

"Where it appears to the Minister for Finance that the interest accrued during any year of account (whether ending before or after the passing of this Act) from the securities standing to the credit of the Post Office Savings Bank Fund exceeded the total of the interest paid or credited to depositors during such year of account in pursuance of the Acts relating to the Post Office Savings Bank and the expenses incurred in such year of account in the execution of those Acts, the said Minister may in the next financial year after such year of account or (in the case of a year of account which ended before the passing of this Act) in the next financial year after the last of such years of account."

The object of this amendment is to clear up a drafting point and to make it clear that interest accruing in the years prior to December, 1929, can be appropriated.

Amendment put and agreed to.
Question proposed: "That the Bill, as amended, be received for final consideration."

On that point I would like to say something with regard to Section 20 of the Bill which, owing to the exigency of time, I had not an opportunity of referring to on the Second Reading of the measure. This is a section which, in fulfilment of the terms upon which the Third National Loan has been issued, gives the Minister authority to accept stock in that loan at par value in discharge of any death duties which may be due to the State. This is an important special taxation privilege. I have looked up the figures for the various years since 1926 and I find that, on the basis of the figures for Free State Government securities represented in the aggregate total of the gross personalities of estates dealt with by the Revenue Commissioners in the years 1926, 1927 and 1928, the total amount of stock likely to be presented for death duties in this way will be, I think, not less than £150,000.

In the course of his Second Reading speech I think the Minister stated that the value of the privilege would be about £6,000 per annum; he apparently estimates, therefore, that the amount of stock thus presented will not be more than £100,000. For reasons which I do not wish to go into in detail, because the figures are rather involved, I think that is a low estimate. I am prepared, however, to split the difference with the Minister and to assume that the total amount of Third National Loan securities which will be presented to the Exchequer in discharge of Death Duties will be about £125,000. That is to say, the Minister will have presented to him stock to the nominal value of £125,000, for which he will only have received 93½ per cent. when it was issued, and which on acceptance by him will represent, therefore, a net loss to the Exchequer each year of about £8,100. If we capitalised this on the terms on which the loan was issued we find that the present value of that amount, if it be paid each year, say, over a period of twenty years, is about £268,000, and that, I estimate, will be the total cost of this concession.

What are we going to get for it? I think we will get nothing. I think this is one of those concessions which are very like the ornaments which one sees upon a wedding cake; they appear to make it slightly more attractive but they add nothing to its value.

First of all, the concession as to death duties is of very uncertain value to the recipient. He does not know how soon his heirs will have the privilege of presenting stock, which he bought at 93½, to the Minister and getting credit from the Minister for it at £100. Even a patriarch may be an optimist in this matter. I certainly have no doubt that a person, who invested in this Third National Loan, even if he were ninety years of age, would still hopefully aspire to celebrate his centenary. We may be quite certain, therefore, that a person buying a loan with this kind of concession attached to it discounts it to the very uttermost. I have absolutely no doubt that the concession in the particular case of our Loan, counted for nothing in the minds of most of the individual investors who purchased this stock, that it was something which the Minister simply gave away without getting any adequate value in return. If you consider the fact which I have put before you that even the oldest of us hope to live more than the allotted span, and if you also bear in mind that it is their heirs more than the individual purchasers of the stock who will benefit by a concession of this sort, you can see, as I have said, that this kind of concession makes the stock very little more attractive than it would be if the concession had not been attached to it at all. I submit that it would be far better for the Minister to have faced this matter boldly, and even if he had to fix the nominal rate of interest on the loan at a slightly higher figure it would be better and more straightforward to have done that, because both the State and the investor himself would know where they are.

I have dealt with the reactions of this matter upon the private individual. I have endeavoured to give the reasons why to my mind the concession is not very attractive to him. Neither is it of great attraction at first sight to the corporate investors. In many cases this Loan was purchased by corporations, insurance companies and banks, which will, in due course, I presume, proceed to unload a large amount of their holdings upon the market. When they considered the terms upon which this Loan was issued they looked at the immediate return which it would give them. The thing may appear to them as a kind of catch-penny concession which, as soon as its value becomes appreciated by a certain number of people—and that will take time—will enable them to dispose at a fairly substantial profit of the stock which they have purchased. A bank buying stock buys it upon the basis of its nominal rate of interest, in this case 4½ per cent., and upon nothing else. In the course of a year or so it may proceed to dispose of it to its customers. There will be a certain number of elderly men to whom the manager may tactfully hint that it would be a good thing for them to transfer their holdings from the First or the Second National Loans into this, simply because of the fact that if by any chance they should pass away at any date subsequent to six months after the transfer of the stock to them their heirs would get a very substantial benefit from the Exchequer. Some may accept that point of view and may buy. But remember this will be merely a transfer, I submit— on the figures for the past three or four years—from one form of Government security to another. You will have people realising their holdings in First and Second National Loans and investing them in the 4½ per cent. Loan. What will be the effect? You will have the 4½ per cent. Loan appreciate in the market and you will have the 5 per cent. Loan correspondingly depreciate. At the same time you will also have this effect, that every future Minister for Finance will have to accept at its face value stock which his predecessor issued at 93½ per cent.

I think that is simply another case of what is being so often pointed out from these benches, of the Minister's predilection for mortgaging the future. If he can tide over today he does not give a thought for to-morrow. It does not matter to him that every year this will make it incumbent on his successors to find an extra £8,100 for which they receive no adequate return. If there is anybody in the community who will get benefits from the concession in Section 20 it will be those large corporate investors who bought this stock in the hope that later on, when they could point out to individual investors the advantage that that section might afford them so far as their heirs' liabilities for death duties are concerned, who will be able to make a profit.

I do not want to be unnecessarily insistent, but I have asked the Minister two or three times to tell us exactly what is the financial significance of one clause in this Bill, the one which makes the Electricity Supply Board liable for income tax. I asked the other day what amount of actual new obligations for income tax was put on this Board. The contention by him was that the obligation was there all the time. The evidence of very competent lawyers to the Electricity Supply Board is that they did not think so, and the Board refused to pay it. We want to know what is the amount involved in the matter. As far as I can see it the position is this, that the Electricity Supply Board, quite apart from the submerged assets, are concerned with the interest and the sinking fund of the two sums already voted by the Dáil, the six million pounds and the £2,500,000, which undoubtedly will be £3,000,000, and in the course of time possibly £5,000,000 or £6,000,000. I asked the Minister whether they paid income tax on that, and he replied, "Interest paid to the Exchequer will be allowed as an expense." That is equivalent to the income of an ordinary firm functioning in the same way. The interest which the Electricity Supply Board will pay upon their borrowed money is, as far as I can understand, exactly equivalent to the dividend which is paid by an ordinary company upon capital invested in that company. The sinking fund would be equivalent to a repayment of capital. Of the two it seems to me that interest on the actual capital is much more directly equivalent— at any rate is, at least, as directly equivalent—to profit. The sum involved would be somewhere about £6,000,000, of which at least three-quarters would be interest, and probably less than one quarter would be sinking fund. This clause ostensibly makes them liable for income tax and, according to the explanation given by the Minister, it makes them liable for one-fourth of the income tax. That is as near as I can understand the position.

The actual income tax which they would be made liable to in this Bill, if they were an ordinary commercial firm, leaving out the submerged assets, would be, at least, £50,000 to £60,000. It seems to me that £45,000 of that is not to be collected and possibly £15,000 is. I think the Minister should tell us exactly what are the figures. Another thing I am not at all sure about is this, whether the Bill as it is now drafted does carry out the intention expressed by the Minister. I have made certain enquiries on the subject and, certainly, authorities are not agreed that it will, in fact, do what the Minister says he intends to do in the answer he made to me. I will read the answer again: "Interest paid to the Exchequer will be allowed as an expense." The Board will pay income tax on sinking fund and certain resources which it will create. I am not at all sure that we will not need another Bill to remove doubts as to the difference between the ostensible meaning of this clause and the explanation given by the Minister. I think that point ought to be cleared up. We ought to be told the position exactly. They can calculate very nearly from what they know of the resources and commitments of the Electricity Supply Board what is the income tax to which they are being made liable and what is the income tax from which they are being allowed to be exempt.

Deputy MacEntee referred to Section 20. All I have to say about his remarks on that matter is that he has drawn a picture of what is, in his opinion, likely to happen. The examination that has been made on my behalf does not produce results that agree with the Deputy's anticipations. I think there will be no such sum as £8,100 required any year by way of an advance from the Exchequer to the fund, which it is proposed to create under this section, and I think after a few years the amount that will be required to be advanced in any year will be very small. It is obvious that if £100 were received in stock for payment of death duties, and if the price of the stock had advanced to 98, the amount to be found in any year would only be £2,000. I believe, before the lapse of any great period, that no appreciable sum will be required, and that the total amount that will have to be advanced from the Exchequer under this section will reach a relatively small amount. It depends, of course, to some extent on the course of interest rates, and nobody can with absolute certainty foretell what the course of interest rates will be and, consequently, what will be the price of the Third National Loan after a few years. But I confidently anticipate that it will rise very considerably above the issue price, and that long before the first redemption date it will be quoted at par. When the point is reached that the Loan is quoted at par no loss will arise under this section, and I think the anticipations of the Deputy are not correct.

Undoubtedly the giving of this concession did influence considerably the terms on which it was possible to issue the Loan, and I am satisfied, and those who advised me are satisfied, that it was an advantage to the Exchequer to issue the Loan at the price at which it was issued rather than to refuse to grant this concession and to issue the Loan at a lower price or at a higher rate of interest. With reference to the matter raised by Deputy Flinn, I have nothing to add to what I said already. Obviously, the interest payable to the Exchequer on the advances made by the Exchequer will be allowed as an expense. The amount on which interest will be chargeable or on which income tax will be chargeable is a matter which will depend on two or three factors.

Might I ask the Minister whether the size of the doubt which this Bill is supposed to remove does not amount somewhere between one million and one million four hundred thousand? It is some doubt.

Question put and agreed to.
Fifth Stage ordered for Friday.
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