The risk of investing a considerable amount of money in developing an export trade and then not getting the trade—the ordinary commercial risk that anybody going into business must face which is obviously far greater in competitive international markets than it is in the protected home market. Thirdly, there was the fact that the profit to be earned in the export market, in relation to the capital required for the development of export trade, was substantially smaller than was needed to attract them.
Some of these problems are, I admit, more the immediate concern of the Minister for Industry and Commerce than of the Minister for Finance, and I may perhaps elaborate my views on them when the Estimate for the Department of Industry and Commerce is under consideration here. But it seems to me that if there is to be an organised effort to expand our meagre exports of manufactured goods the reality of these problems has got to be faced: the difficulty of Irish manufacturers in securing capital for the expansion of their activities, their reluctance to face the considerable risks involved in export trade and, thirdly, their inability to earn, in export trade, profits which appear attractive to them.
This report of the Committee on Industrial Taxation shows in a very definite way the capital problems to which I have referred. Only a minority of our manufacturers have got access to the very limited capital market we have in this country, and there are very few Deputies here who would think that an industrial concern proposing to embark into export trade and requiring additional capital for that purpose would be successful in securing public subscription of the capital required. Indeed, even a new firm proposing to engage in production for the protected home market or an existing firm proposing to expand its activities in the protected home market would have difficulty in getting capital by public subscription at the present time. The difficulty is obviously much greater when the capital expansion is designed to finance more speculative export business. Whether it is done by an adjustment of taxation arrangements or whether it requires an extension of the resources and the powers of the Industrial Credit Company, or whether there is some other method, I do not think it is possible to get any substantial expansion in industrial production for export without making capital for that purpose more readily available than it is at present to industrial companies.
So far as the risks are concerned, the difficulties may not, in the event, prove to be as great as the management of these firms now think they are. Most of our newer industries have grown up in the protected home market and they have planned their expansions in the past only when they could see the certainty of the market for the additional goods they proposed to produce and the possibility of selling them at a profit. The Commission on Emigration made a recommendation that there should be set up a co-operative exporting organisation designed to give assistance to private firms entering or wishing to enter the export market and to combine the productive strength of these firms so that they could enter the export market with a sufficient impact to secure permanency there.
That recommendation of the Commission on Emigration has been accepted in principle by the Party on this side of the House. Indeed we ourselves at one time had contemplated the establishment of an organisation of that kind and the Government sanction for the necessary legislation had been secured. It was not proceeded with then because the need was not particularly acute, but few will deny the acuteness of our present need, the urgent need for action to secure this expansion of production and expansion of exports.
So far as the third factor affecting the attitude of our manufacturers to export is concerned, namely, the rather meagre profits that can be earned in export business, I can see no way of meeting that point except along the lines suggested by the Irish Exporters' Association to this commission, that is, by a preferential remission of taxation on profits earned in export business. The Minister for Finance referred to that part of the commission's report where they dealt with that point. The astonishing thing is that the commission did not really deal with it at all. They got this recommendation from the Irish Exporters' Association and in their report they did nothing except print an extract from a memorandum which they got from the Revenue Commissioners regarding it.
I do not know to what extent the members of the committee may have considered the proposal but they have not in their report done more than endorse a very superficial comment on the proposal submitted to the committee by the Revenue Commissioners. Apparently the Revenue Commissioners said the proposal would violate the basic principles of income taxation.
What are the basic principles of income taxation? Is it that there should be no discrimination, with economic objectives in view, between particular forms of income, that all income, no matter how derived, should be subject to the same taxation and that economic objectives are not sufficient to justify discrimination in taxation between different citizens or different forms of revenue? It would be strange if these basic principles of income taxation were relied upon by the Government to justify the rejection of that proposal in a year in which the Minister for Finance himself brought in here a proposal to provide for discriminatory taxation in favour of certain mining companies. When that Bill was presented to this House I made it quite clear that, so far as we were concerned, we did not object to the principle of the discriminatory use of taxation in special circumstances to achieve economic aims.
I criticised the particular proposals in the Bill but there was no opposition to those proposals on the issue of the basic principles of income taxation. I think the Government is fully justified in adjusting its taxation measures so as to induce economic objectives which will serve the national welfare, and in circumstances like those now existing, in which the survival of this State as a business organisation is at issue, then the use of taxation, if it will help to that end, cannot be questioned. But what are the arguments put forward by the Revenue Commissioners? They say that a company set up here to make goods previously imported is making the same contribution to a reduction of the gap in the balance of payments as a company set up to make goods for export. A company which is set up here to make goods previously imported in 99 cases out of 100 has the assistance of protection. It is getting from the community a far more effective form of help, a far more effective assurance that they will be permitted to make profits than is involved in any taxation changes.
Often in the past, I have had to defend that policy of protection here and admit that under it the public were being asked to subsidise in prices industrial projects in the earlier stages of their development, believing that in the long-term the community as a whole would benefit. If we had not the power to protect our industries, if we were in the same situation as they are in Belfast of having to try to promote industrial development without the power of protecting it then we might resort to taxation relief or outright subsidy, but here we have not had to use those devices except in the specific matter of encouraging industrial development in the West and therefore that question does not arise in this connection.
But we have need to expand production for export. Indeed, the Committee on Industrial Taxation itself recognised that we are nearing the end of industrial expansion based upon the home market and that if there is to be a further and significant increase of industrial output and of employment given in the manufacturing industries it has to be through the development of industries for export, and if there is any prospect that we can stimulate that development by a suitable adjustment of taxation on profits earned in the export trade, then it is worth considering. Other countries have tried it. I think it is true to say that the majority of countries in Western Europe have in operation at the present time, discriminatory tax arrangements designed to benefit exports, and they do not consider they are violating basic principles of income taxation in so doing. They approach the problem as a practical one to be solved by practical methods, and our much more acute problem must be approached in the same way.
There is a further argument that as we have an item on the credit side of our international balance of payments, in our receipts for tourism, that hoteliers might look for the same concession. I do not know whether tourists come here because of our hotels or, as has been said, in spite of them. That is a question we have argued in the past, but it is certainly not the hotels alone that bring them here and to that extent the argument is fallacious. But I think the hoteliers have a legitimate complaint against the operation of the present tax code. There is no doubt that tourism is a most important item on the credit side of our balance of payments. I think it is the second largest economic activity carried on in this country and we could expand it, I am sure, a great deal more and make it of greater importance than it is. But why does the hotelier not qualify for a depreciation allowance on his hotel just as the owner of industrial buildings is now being recommended for a depreciation allowance? Is not the wear and tear on furniture in a hotel just as important an item in the accounts of the hotel proprietor as the wear and tear of machinery in the manufacturing industry? Far be it from me to argue that the volume of the tourist trade cannot be stimulated by a suitable adjustment of taxation also.
It seems to me, therefore, that the Committee on Industrial Taxation failed in the task that they were given to do in so far as they did not tell us their own views upon this proposal advocated by the Irish Exporters' Association and advocated from this side of the House during the course of the Budget debate that there should be an inducement held out to firms in this country to enter into export business, through a reduction in the income-tax on the profits earned on that business. We can parade our principles of taxation as a justification for doing nothing: we can rely on various excuses to justify inactivity, but something has to be done whether through one method or another. This country has got to bring about in the near future a very substantial increase in production and an equally substantial increase in exports.
It is not enough for commissions, committees or Ministers to come and tell us what cannot be done if they will not tell us in their view what can be done. In my experience—and I have checked that experience, as I said, recently by contact with the people in charge of industrial projects that are capable of doing export business in the sense that they are producing goods of a quality and at a price which appear to me to be comparable with goods on sale in foreign countries—I found that there were three main factors holding them back: in some cases inability to get the capital required for the expansion of their activities; hesitation about embarking upon that new capital liability because of the greater risks involved in the export trade and thirdly, the lack of inducement such as this tax concession would give. I feel quite certain, knowing the mentality of many of these people, that if there was held out a prospect of relief of tax in accordance with some sliding scale on profits earned on exports that it would have a very considerable influence upon their decisions in that connection.
The committee say in their report:
"We are doubtful, however, if income taxation provides the most suitable channel for concessions of this nature and we agree that aids to the development of industrial exports should be the function of some Department other than the Revenue Department."
For myself I have little doubt that an adjustment of income taxation would be a very effective stimulus to industrial producers to go into exports and if the Government do not agree with that, then it is for some other Department to come forward and say what alternative measures they are proposing to take.
I do not think that any adjustment of taxation to secure economic results need necessarily be permanent. Economic conditions change from time to time and the taxation system must change with them, and the proposals which I am advocating now here, the point of view I am urging, relate solely to the circumstances existing now and particularly to the urgency of our need to get an increase in production and increase in exports.
However, let us take the recommendations made by the committee as they stand. They recommend that there should be an increase in basic wear and tear allowances of 25 per cent. on industrial plant and equipment and that there should be introduced an initial allowance of 20 per cent., and that so far as industrial buildings are concerned there should be a depreciation allowance in their case also, with a 10 per cent. initial allowance.
The Minister has adopted in advance of the publication of the committee's report and embodied in this Bill, a recommendation for the introduction of an initial allowance on plant and machinery. I think that he would help considerably to secure amongst those who are in charge of the industries of the country an attitude of mind which will encourage them to expand if he will say now that the other recommendations of the committee will also be adopted, even if they are not implemented until the 1957 Finance Act. If he is not prepared to say it now, he should think of the desirability of saying it soon because the mere announcement of the Government's intention to give effect to the whole of the recommendations of the committee would itself have a stimulating effect. Certainly, I urge that the decision on these recommendations should not be postponed until the Budget of next year. There is no question of any cost involved. Even the adoption of the one recommendation concerning the introduction of an initial allowance on machinery involves no cost to the Exchequer in this year.
I see that the Local Government Officials' Trade Union has urged that the recommendation be not adopted at all until the whole tax code has been submitted to examination. I hope the Minister will tell the Local Government Officials' Union or any other officials' union that the ability of this community to keep on paying the salaries of officials in their present number will depend entirely upon the effectiveness of the measures that may be adopted this year to secure the expansion of production required to rectify our balance of payments position.
There is, however, one aspect of the proposal as set out in Section 23 of the Bill to which I want to refer. The section provides that the initial allowance will be one-fifth of the expenditure incurred after the 6th April, 1956, by any person upon plant and machinery and for the purposes of the section the expenditure is deemed to be incurred on the day when the sum in question becomes payable.
I do not know why that particular form was adopted in the section. It is a departure from all the principles upon which the calculation of wear and tear allowance was based in the past. Under the existing regulations of the Revenue Commissioners, the wear and tear allowance begins to be calculated only from the day on which the plant or machine goes into productive use. It does not matter when it is paid for or if it is never paid for or how long the plant may have been lying idle although installed in the workshop, it is from the day it goes into productive use that the wear and tear allowance is calculated and this introduction of the day upon which the plant is paid for as the critical date seems to me to be an important innovation in our tax code and a very undesirable innovation. I do not know what the Minister has in mind in that regard. What does he mean by the term, "the day upon which the sum in question becomes payable"? Will there not be innumerable legal cases taken to the law courts to determine the meaning of that phrase? When does the sum due in respect of a new machine purchased by a manufacturer become payable? Is it payable on the date on which he orders the machine or is it payable on the date on which he completes the payment for it?
In the great majority of cases that I know of any substantial outlay on industrial plant involves payments spread over a period of time. It is not unusual that an instalment has to be paid on the placing of the order, a further instalment paid on the completion of the plant in the manufacturer's workshop and a further instalment after the plant has been erected or perhaps even after it has been in use for some months in the factory of the purchaser. When is the sum payable? From what date will the initial allowance be calculated?
A number of firms who are interested in this proposal have been bringing their difficulties to me. I am sure some have been brought to the Department of Finance also. I have personal knowledge of one case where a contract has been made for the purchase of a substantial amount of plant for a new factory on terms which will not involve payment for that plant for three years. The plant will be in use, however, and the ordinary wear and tear allowance will be made in respect of that plant from the day it comes into use. Will the initial allowance in this case not be made until the final payment for that plant is made, long after it has gone into use, or is it to be made on the day on which the plant is introduced?