We certainly would agree with that amendment of the amendment. It is a distinct improvement on the position that was being presented under the amendment as tabled. For that we would like to express our appreciation. Nevertheless, the whole position arising here is totally unsatisfactory and that there is a patching-up effort having to go on in order to get some degree of reasonableness, and I say only some degree, into the situation. As the amendment was tabled it was designed to deal with the situation as it arises but the position is that this Bill is likely to be passed by both Houses of the Oireachtas about 20th August and if one took the date in the amendment as tabled, 5th October, that would have left about one and a half months in which to peruse the final form of the Bill, to assess oneself correctly and to pay tax. Otherwise, one would have been liable to interest and that interest would be at 18 per cent per annum from 5 April to the 5th of the month following payment. I would regard that as a most iniquitous and penal provision. What the Minister has announced is a considerable improvement.
We must not lose sight of the fact that all of this tinkering with the dates for 1975 arises, not because, as is sought to be suggested from the Government benches, of filibustering or unreasonable opposition on this side of the House. I would venture to suggest that the Opposition's performance on this and on the other capital taxation measures will be shown from the record to have been detailed and conscientious effort on the part of the Opposition to deal with what are very difficult and complex Bills. The real problem arises because of two things: one, that the Government were very dilatory in bringing forward the Bills. They should have been produced much earlier than they were. I do not think that the Minister can contest that statement.
If some kind of charge analagous to the 18 per cent interest rate were to be imposed on Members of the Government in respect of their dilatoriness in this matter, they might take a different view of the situation and their approach would be more equitable than it was in the amendment as tabled.
The other matter that causes the difficulty is one to which I referred last night, that is the fact that the White Paper said that the commencement date for the wealth tax would be 6th April, 1975. It also said that the wealth tax would be charged on one particular day in each year, probably, it said, 5th April, which is the last day of the tax year. It did not commit the Government to 5th April as the valuation date but it said it was likely. But it did say specifically that the commencement date for the wealth tax was 6th April. The clear implication of that was that what the Government intended to do was to charge an annual wealth tax but, for technical reasons which were spelled out in the White Paper, it would have to be based on wealth on a particular day, that the valuation date likely to be chosen for that was 5th April in each year and that consequently what was intended was that wealth tax considered as an annual tax would commence on 6th April, 1975 and that the first valuation date would be 5th April, 1976.
If that had been adhered to we would not have the kind of problems we are faced with in this amendment and now the amendment to the amendment given by the Minister, because there would have been adequate time to process this Bill through both Houses of the Oireachtas, to give taxpayers and their advisers a reasonable opportunity to consider the implications, to make preparations, to get valuations where they were necessary, and to operate the wealth tax in an orderly way.
I believe the plans as outlined in the White Paper would have ensured that but, for some reason—one can speculate on the reason; I have a fairly good theory as to why this was changed but that is irrelevant—the Government changed their minds and departed from what was said in the White Paper and, instead of doing what was proposed in the White Paper, which was to have the wealth tax commence on 6th April, 1975, and to have the first valuation date 5th of April, 1976, they departed from that and tried to rush it through a year earlier. This led to all of the difficulties we have been faced with, long sittings, amendments and amendments to amendments. All of this gets back to the departure from what was clearly set out in the White Paper. As I say one can speculate on the reasons, but that may not be relevant here.
The fact is that all of these difficulties have arisen and they have arisen not, I repeat, because of unreasonable Opposition in this House, but because of two things, both attributable to the Government. One, the failure to bring forward the legislation, to publish the legislation in reasonable time and, two, the departure from what the White Paper said was going to be the programme for implementation of the wealth tax. All of that has led to all the difficulties we have had with this Bill: the long sittings and the amendments which have had to be put in and now the Minister has had to amend the amendment again. It is unfortunate that it should be so, but if it is so let it be clear why it is so. I do not think that it is open to the Minister to contend, as he tried to contend last night, that the Government did not say in the White Paper, and make it quite clear, that what they intended was to have as the first valuation date for wealth tax purposes 5th April, 1976, although the Bill now says 5th April, 1975. Just to refresh the Minister's memory on this, let me remind him that paragraph 93 of the White Paper said:
The wealth of the taxpayer would be valued on, say, the last day of the tax year, at present the 5th April.
On page 60 of the White Paper it is stated:
Annual wealth tax: The date of commencement will be 6 April, 1975.
There is, I suggest, a significance in the fact that it says 6th April and not 5th April. Any reasonable reading of this White Paper—and I can confirm that this is how it was read by numerous people—shows that the commencement date would be 6th April and the first valuation date would be 5th April. If that reading is not correct, the only other possible explanation is that the Government are charging wealth tax in advance. If it is to commence on 6th April and the first payment date is 5th April then it is being charged in advance. The Minister denied strenuously last night that it was being charged in advance.
If it is not, the only other possible reading of the White Paper is the one I have put forward and the one that I am quite sure is what the Government intended, which was to have as the first valuation date 5th April, 1976, and that would have allowed for a reasonable processing of the Bill and implementation of all the necessary measures both on the part of the Revenue Commissioners and on the part of taxpayers to operate this measure smoothly. Instead of that, for whatever reason, we have had the very unsatisfactory manner in which this Bill has had to be dealt with in this House. Now we are operating under a guillotine because of the failure of the Government, on the one hand, to bring forward the Bill in adequate time and, on the other hand, the failure of the Government to adhere to what they stated in the White Paper as the programme for implementation.