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Dáil Éireann debate -
Thursday, 20 Apr 1989

Vol. 388 No. 10

Finance Bill, 1989: Second Stage (Resumed).

Question again proposed: "That the Bill be now read a second time."

First, I would like to thank all the Deputies who have contributed to the debate and to respond as best I can in the time available to the major issues which were raised. The points relating to individual sections of the Bill can be discussed in greater detail on Committee Stage.

To take up briefly one or two points made by the last contributor, Deputy Durkan, it is a rather confused argument that he is trying to put forward, if I follow him correctly. In the first instance, he argues about mortgage interest relief and at the same time is seriously concerned about the huge increase in house prices. There are many economic commentators out there who would say that the existence of mortgage interest relief is a contributor towards that situation.

It is not a major contributing factor in this case.

Secondly, he talks about a fictional reduction in taxation as against the reduction in mortgage interest relief. I do not know what sort of calculator he used to arrive at that conclusion.The change in the mortgage interest relief will bring in between £18 million and £19 million, but the tax reduction in the same budget will cost £200 million, both in a full year.

But not to the same people.

There is a ten to one ratio. I do not think that I need say any more than that.

Some people are penalised more than others.

There are 600,000 odd taxpayers who got taxation relief in that budget and only a section gained mortgage interest relief. Whether they are on the 35 per cent, 48 per cent or 58 per cent band, they all got relief. We shall leave it at that.

Deputy Durkan talks about giving relief on stamp duty. There are plenty who would argue directly against that and say that if those people have so much money that they can pay these top of the market prices for houses, perhaps the stamp duty should be increased. It is rather contradictory.

I am talking about a house price of £30,000.

Let the Deputy not be afraid. We are fully immersed in the spirit of 1992. The Deputy would not buy a pig in a poke being the good farmer's man that he is and I have no intention of doing that in relation to the harmonisation which must take place for 1993. I shall await the revised proposals in relation to this matter which will be put on the table, it is hoped, next month in Brussels. The previous proposals will not be implemented in the form in which they have existed for the last two years. I do not think that any reasonable person would expect me to buy a pig in a poke. I see that Deputy Noonan has joined us and I have a few responses to some of the questions he raised.

(Limerick East): I am sorry I was not here when the Minister commenced. I always enjoy what he has to say.

I was surprised at what much of the Deputy had to say in this debate in response to the economic strategy of the Government. He has chastised me for "failing to use the power at my disposal to cure the problems of the economy".This is the kind of exhortation that I would expect from a man who believes that there are instant solutions. Why were the instant solutions not applied by the Deputy and his colleagues when they were in office, to turn the tide long before the crisis had emerged in 1986? I know that Deputy Noonan is not a man for instant solutions but I recognise that in Opposition he must make the best of the material that is available to him. We all know why that Government did not introduce those instant solutions. It was because there were no simple easy solutions then and there are none now.

(Limerick East): The subversives in then Opposition helped out on that.

Simple solutions were followed in the past and were self-defeating.I have said, frequently, that we need to maintain our sense of realism, and that we must see recent progress as no more than the start of a process. It will take a long time to make major inroads into the problems of unemployment and emigration.There is no doubt, however, that the policy approach we are following is producing the results. It provides a coherent basis on which industry and business can increase investment and jobs. This is why industry welcomed the budget and are increasing their investment on foot of it. I do not understand how anyone can represent the Government's desire to stick with a policy approach as one of inactivity.

The plain fact is that employment has begun to recover, following a long period of decline. This is borne out by the results of the 1988 labour force survey published last autumn, and by more recent data on building and manufacturing employment.It is also reflected in the falling level of unemployment. These are the welcome results of the Government's responsible economic and financial approach.

The Government's overall strategy is now fully set out in the National Development Plan. The plan spells out the problems facing the economy and the nature of the actions necessary to resolve those problems. It presents the strategy which this country must follow, if we are to build on the solid progress already made and to fully exploit the opportunities of the future. It is, with the Programme for National Recovery, the blueprint within which budgetary and general economic policy is being, and will be, framed each year.

To view the plan as "proposing solutions which are unreal or inadequate" simply because it does not precisely detail each and every action which might be taken right up to 1993, is to misunderstand its purpose and its relationship with annual budgeting. The measures taken in the 1989 budget are fully consistent with the national plan. The budget had as its underlying objective the promotion of sound economic activity and sustainable employment throughout the economy. The supplementary development budget was included in the overall budget to make sure that we would lose no time in increasing the level of investment in the economy, with the assistance of the EC Structural Funds. The budget also made major progress on social welfare and on tax reform, both of which are so closely tied in with unemployment. The House can be assured that over the period of the National Development Plan the annual budget will continue to implement in detail the policies set out in the plan.

Deputy Noonan further chastised me for "giving little lectures on the evils of inflation", saying that I "have the solution in my own hands". This is nonsense.

(Limerick East): The Minister would want to talk to the Minister for the Environment.

Inflation is a function of external prices — which, as a small nation, we can do little to control; and of domestic factors, principally trends in wages, profits and taxes, which we can control. We have got our inflation down to very low levels and are determined to keep it there. Close control of domestic costs is the key to this. Taxation policy, under this Government and within the constraints of prudent budgetary policy, has underpinned low inflation, in marked contrast to the years before.

I was even more surprised by the way the Deputy put his proposition that "there is scarcely an economic or social weakness which could not be remedied to some degree by an appropriate taxation response". He specifically advocated reduced VAT and excises to cut into transport costs; radical reform of the personal tax system, pointing particularly to high marginal tax rates; and lower VAT and excises to support tourism growth. Of course, these would help, but in the short run only, unless accompanied by measures which offset their adverse budgetary impact. Did his courage fail him on this score? He made no mention of offsetting tax increases or expenditure cuts. The only conclusion I can come to is, then, that he wants to increase borrowing once more. We cannot solve the problems of this country by giving a new tax incentive each time we have a difficulty, nor can I understand how such an approach could be reconciled with the need to get personal taxes down further. It is a lesson that everybody has learnt — high borrowing means high taxes.

Regarding the matter of special pay increases referred to by Deputies McDowell and Desmond this question must be viewed in its correct context. The public service pay agreement has been a vital component of the success of the Programme for National Recovery. Since 1987, it has enabled special pay claims to be processed through the agreed machinery but has postponed the payment of any awards or settlements for a considerable period of time. The agreement also provided for discussions to be held if the Government considered that the payment of such increases would put at risk the central objectives underlying the Programme for National Recovery. Talks on the whole question of special increases are currently under way between my officials and the Irish Congress of Trade Unions.

I would like to make two other points on the issue raised. The figure of £150 million mentioned is the ultimate full year cost and there is no question of this amount being paid in the short term. Furthermore, the processing of claims through the existing industrial relations procedures has preserved peace and order in industrial relations — a fact which is clearly borne out by the statistics on industrial disputes over the past two years. I presume that Deputy McDowell is not suggesting that the Government should replace this approach by unilateral and confrontational measures. This Government have always favoured dealing with such matters by way of consensus rather than confrontation.

Both Deputies Noonan and McDowell were critical of what they saw as the Government's lack of commitment to tax reform particularly in the area of personal taxation. Here again, however, actions speak louder than words. The fact is that we are reducing personal taxation in a concrete way, not engaging in theoretical debate about what might or might not be done.

I want to assure the House that we fully accept that income tax rates are still too high, however, and that the income tax burden is too heavy. We fully accept that it is acting as a disincentive to effort and enterprise and hampering the drive to increase employment. We have a very simple plan for income tax: we want to get it down. But unlike Opposition speakers, we have not got the luxury of talking about income tax in a vacuum. We have to take other priorities into account, most notably the overriding necessity for rigorous control of public expenditure and firm management of the economy. Tax reform is part of the solution needed to our problems but measures to achieve it must be consistent with the overall policy approach.

I would have to go on to say that, contrary to what Opposition speakers have implied, we have made very considerable progress on income tax in the short period since we came to office — a period which, I would remind the House, demanded, and got, outstanding management of the public finances. In the autumn of 1987, the Government negotiated the Programme for National Recovery with the social partners. The programme committed the Government to introduce income tax reductions to the cumulative value, over the three years of the programme, of £225 million, including increases in the PAYE allowance costing £70 million. In the 1988 budget, my predecessor introduced income tax reliefs costing over £150 million in the 1988-89 tax year. These included increases in the personal and PAYE allowances and in the general and age exemption limits and a major extension of the standard rate band. These reliefs more than fulfilled the Government's commitment on the PAYE allowance and increased to nearly 63 per cent the proportion of taxpayers paying tax at no more than fulfilled the Government's commitment on the PAYE allowance and increased to nearly 63 per cent the proportion of taxpayers paying tax at no more than the standard rate. On a cumulative basis, they are estimated to cost over £400 million over the period of the programme — or nearly double the £225 million undertaking contained in that programme. In other words, within a few months of negotiating the programme, the Government had fulfilled — and far more than fulfilled — all the commitments on income tax relief contained in it.

We have not, of course, stopped there. In this year's budget I provided income tax reliefs costing over £200 million. They were aimed at improving the position of low-income taxpayers and especially lowincome families at reducing the pro-gressivity of the system and maintaining at nearly 63 per cent the percentage of taxpayers paying tax at no more than the standard rate, and finally, at reducing income tax rates themselves. On a cumulative basis, over the remaining period of the Programme for National Recovery, they will provide more than £300 million in income tax reliefs on top of last year's package. In total then, as I indicated earlier, the Government will have provided more than £700 million worth of income tax relief, compared with the programme commitment of £225 million. We have, in short, given more than three times the amount we undertook to provide in the programme. These are not the actions of a Government which has no will to deal with income tax; they are, rather, the actions of a Government which is quite clear about the need to reduce the income tax burden.

Contrast this with the parties opposite. Deputy Noonan's party last year put forward a document calling for the introduction of a two rate system of income tax which was estimated at the time to cost about £660 million in a full year. No details were provided in the document to indicate where this money was to be found.

Deputy McDowell's party also brought out a document last year which, though very specific on the income tax and PRSI concessions to be in place by year five, was less than specific on what was to happen in years one, two, three and four. It was also vague on how the concessions were to be paid for. To take just one example, it suggested cuts of £165 million a year in public expenditure to be in place by year five, but it was silent on where exactly the axe was to fall.

These are luxuries not afforded Governments. When a Government bring forward their budget and Finance Bill, they must say clearly not only what reliefs they are providing, but also how they will be paid for. They are not permitted to point to vague generalities — they must make specific proposals. Here I should point to another contrast with Opposition Deputies in connection with mortgage interest relief. This year's Bill provides, as Deputies are aware, for a small reduction — from 90 per cent to 80 per cent — in the amount of interest which will qualify for relief. It is a measure which is estimated to raise £18.3 million in a full year, to help in a minor way to meet the cost of the overall package of income tax reliefs which, as I have said, is over £200 million. What happens? Are the Government congratulated for extending the tax base and bringing down tax rates, as would be expected by anyone reading Opposition documents on tax reform? On the contrary, Deputy Noonan signals his intention to put down an amendment to have this small restriction restored if interest rates rise, while Deputy McDowell wants a special concession for fixed rate mortgage holders. In exactly similar vein, Deputy Barry Desmond criticised us for not reducing our three rates of income tax to two, and talked of the imperative need for simplification; but he omitted to mention that his party's recent policy document recommended, not two, not three, but four income tax rates!

I repeat — we are the ones who are serious about reducing the burden of income tax. We have shown this, not by issuing vague and idealistic policy documents but by bringing realistic and costed proposals into this House and by far exceeding our undertaking in the Programme for National Recovery. We have made significant progress on income tax reductions already and we will make a lot more in the years to come.

(Limerick East): Thank God.

On the wider question of 1992 and the achievement of a Community-wide indirect tax system, I have already stressed on a number of occasions that it would be premature for me to make substantial changes to our existing régimes when so much uncertainty remains over the final shape of any Community package. The Commissioner with responsibility for this area. Madame Schrivener, has now signalled very clearly and publicly her intention to bring fresh thinking to bear on the earlier proposals, which as we all know have been around for a long time and on which no significant measure of agreement could be wrought She also intends to bring fresh thinking to bear on excise duties. Deputies will be aware that had the implementation of the earlier excise package gone ahead, it would have resulted in massive annual revenue losses and substantial distortations of existing price relatives on the domestic market. Concern had also been expressed in medical and social circles about the potential implications of large reductions in the duties on alcoholic beverages and tobacco. For these reasons both my predecessor and myself expressed forcibly, on numerous occasions at the Council of Finance Ministers in Europe, the need for judicious amendment of the excise proposals. The indications are that these interventions have had the desired effect.

As I indicated in my opening address, the revised proposals from the Commission on VAT and excises are due to become available around mid-May — so much for the hypocritical nonsense of asking me to buy a pig in a poke and take a step into an unknown arena. I certainly will wait to see the proposals before shaping my response to them.

(Limerick East): You will not slide out of that one. You, Minister, have to make the decision.

Deputy Noonan dwelt on the harmonisation of VAT and excise duties, particularly as they relate to the transport and tourism sectors. The Deputy should be aware that VAT is a recoverable expense for most businesses, so the effect of VAT rates is of a cash flow nature only. Excise duty on articulated trucks, to which he specifically referred, is as low as 6.5 per cent. In regard to tourism services I am glad to say that our rates compare very favourably with those of our European partners. Hotel accommodation, meals, car, boat and caravan hire and tour guide services all benefit from our low 10 per cent rate and I know from my own dealings with tourism interests that they fully appreciate this favourable VAT treatment.

I accept that trade distortions have arisen on either side of the Border, and that these have been due in part to differentials in taxation. What the Government have been doing on the taxation front is well known to all — since 1987 increases in indirect taxes have been kept to a bare minimum. This, as well as the 48-hour rule, have improved the position greatly. Deputies will have read in recent days of the survey taken on the price differential that now exists between North and South and will have seen that the gap has narrowed right down, as a result of the progress we have made over the last two years.

The excise licence increases proposed in the Bill with one or two exceptions, are generally in line with inflation, calculated by reference to the last increase some years ago, with a small degree of rounding up to avoid awkward fee levels. As I have already said, this opportunity is being availed of to create a petrol dealers' licence as an aid to combating the smuggling of petrol from Northern Ireland. There is already in existence a hydrocarbon dealers' licence which covers auto-diesel.

In relation to Deputy Noonan's comments on the provisions in the Bill which increase the livestock rate of VAT and the farmers' flat rate refund I would refer the Deputy back to the Taoiseach's statement on this matter on budget night when he explained that, as the farming sector still owe a certain amount of health contributions and levies, the move towards restoration of flat rate refund should only be partial. Nevertheless, this year's adjustment is significant in that it involves a transfer of £12 million to farmers in 1989 and £17 million in a full year.

Deputy Noonan asked whether the proposed limit of £2.5 million on the amount a company or companies can raise under the business expansion scheme was an annual or a once-off limit. The limit is in fact a once-off limit — no company will be able to raise more than £2.5 million under the scheme. This figure will take account of amounts raised before the date of publication of the Bill: in other words, where a company has already raised BES funding and is proposing to raise more, it will only be able to raise under the scheme the difference between what it has raised and the £2.5 million limit. The Deputy also asked about the justification for removing leasing from the coverage of the scheme. The reason for this exclusion is the fact that the benefit of a substantial proportion of the tax forgone on investment in equity in such companies would flow abroad. In other words, the benefit of our tax foregone would flow elsewhere.

Deputy Noonan had a number of queries about the restrictions in section 19 regarding section 84 loans. First, he asked about the cost involved to the Exchequer. The cost to the Exchequer of domestic-sourced section 84 loans has greatly increased in recent years. According to the Revenue Commissioners, the estimated net cost has increased from about £58 million for 1986 to about £80 million for 1988. This increase in cost is due to two factors, namely, the increase in the volume of these loans and the increasing use of loans in high-interest rate currencies. The total amount of domestic-sourced section 84 loans as of last February was almost £1,300 million, an increase of about 65 per cent over the corresponding figure for February 1986. Also, the high-interest rate type of loan in currencies such as the Greek drachma and the Australian dollar has become much more common in the last two years. These loans are much more expensive to the Exchequer than the normal Irish pound section 84 loans because the bank involved borrows the funds at interest rates of between 14 and 23 per cent as against about 8.25 per cent for an Irish pound loan. This results in the bank receiving a considerably higher amount of tax-free section 84 interest as well as having much higher funding costs for offsetting against the taxable income from other lending.

Secondly, Deputy Noonan referred to the effect of the proposals on Shannon companies. Manufacturing companies in the Shannon Airport zone will still be allowed to borrow domestic-sourced section 84 loans. Non-manufacturing companies in the zone, who in fact borrow the bulk of the high-interest rate loans I have spoken about, will not be able to borrow new domestic-sourced section 84 loans from 12 April. They will, however, have until 31 December 1991 to phase out their existing loans, which is a very generous phasing out period. In addition, they will still be able to borrow foreign-sourced section 84 loans, of which they already make considerable use. The leading leasing company in Shannon are reported in the press to have indicated that the changes will not impinge on their business. The effects on two of the other main leasing companies have been described as minimal and not serious respectively. The changes in section 19 will put such Shannon financial companies in the same position as companies in the International Financial Services Centre which are already debarred from borrowing domestic-sourced section 84 loans.

Thirdly, the Deputy asked about the implications of the changes for the IDA and SFADCo incentive packages. The key taxation element in these packages is the special 10 per cent rate for manufacturing and Shannon services companies and this, of course, is unaffected. In addition, manufacturing companies will still be allowed to borrow domestic and foreign-sourced section 84 loans for manufacturing. All licensed services companies in the Shannon Airport zone were specifically exempted from the reduction in the 1988 Finance Act — in the first year 100 per cent capital allowances in plant, machinery and industrial buildings, and this relief is particularly valuable to the leasing companies located there. Finally, as well as tax reliefs, the IDA and SFADCo packages also contain important grant and other non-tax elements.

I would like now to turn to the points Deputy Yates made last night about the disabled drivers' scheme, and about my reply to a parliamentary question about a particular case tabled yesterday by Deputy Yates. I said in my reply to the Deputy, and I quote:

I am having the legislation looked at again and will be in touch with Opposition spokesmen with a view to including a possible amendment in the Finance Bill at present before the Dáil. The question of a refund of excise duty in the case in question will be sympathetically reviewed in the context of any resulting amendment to the disabled drivers' scheme.

As the foregoing reply demonstrates, I am most anxious to reach an amicable solution to this issue. There is no question of the Government or I wishing to prevent change in unsatisfactory aspects of this scheme. This is proven by the fact that it was my predecessor who last year initiated a move to have the existing taxbased scheme replaced by a new expenditure-based scheme. In the event agreement to this move was not forthcoming.

In any change in a scheme of this kind, it will be necessary to ensure that those who in medical terms require this assistance are properly targeted while avoiding the possibility of abuse. To this end, and in proof of my good faith in this matter, I have already undertaken to arrange discussions with Opposition spokesmen on possible changes to the existing disabled drivers' scheme and have invited suggestions as to how our objectives can best be achieved. My aim will be to arrive at an agreed change to the terms of the existing scheme which will make it more humane and effective.

I welcome the support in principle expressed from all sides for a general anti-avoidance provision. It is quite clear that, with the ever-increasing sophistication and complexity of schemes to avoid payment of tax, something has to be done to retrieve the balance in favour of the general body of taxpayers. This is the motivation behind the provision in section 76 of the Bill.

A number of Deputies — notably Deputy McDowell, Deputy Noonan and Deputy O'Malley — raised specific points and worries which they have about the section as drafted. I will be happy to discuss the issues raised when we go into detail on the Committee Stage. At this juncture I would just like to underline again some of the procedures and safeguards which are built into the section.

The Revenue Commissioners will be required to act in a reasonable way. They cannot move to disallow a tax benefit under the provision until they have given the person concerned adequate time to challenge, through an appeal, the Revenue opinion that a transaction is aimed primarily at tax avoidance.

In hearing an appeal the Appeal Commissioners or the Circuit Court, as the case may be, will be able to look at all the facts relevant to the case, including the form and substance of the transaction and its final outcome and any information not previously made available to Revenue, to see if, on all the facts, the Revenue Commissioners' opinion is correct. Only when this process is concluded, and provided the outcome of the appeal is in their favour, can the Revenue Commissioners take action to follow through on the opinion they had formed.

As I mentioned in my opening address there are other specific safeguards built into the section for genuine business transactions and the taking up of recognised tax reliefs. These safeguards would explicitly limit any use of the section by Revenue to interfere with bonafide transactions and would represent a very definite direction from the Oireachtas to the Revenue Commissioners in this regard. The discretion given to the Revenue in this area would extend only to action against tax avoidance based on an abuse of relief provisions. This degree of discretion is necessary if the whole purpose of the general anti-avoidance section is not to be nullified.

As regards, the effective date of operation of the section, I would stress that there is no question of going back to reopen tax settled many years ago, as some Deputies have suggested. Our concern is just to ensure that tax avoidance schemes entered into before budget day will not affect the Exchequer for many years to come. This whole section is an important one and I look forward to returning to it and discussing its scope in detail on Committee Stage.

Some Deputies expressed concern about the introduction of the annual accounting option for small-scale employers and traders. Deputy Noonan was worried about the cash flow effect on traders and Deputy Mac Giolla was concerned about possible abuse by employers.

I would like to stress that only very small-scale traders and employers will be involved in this scheme and the amount of revenue involved is only a minute fraction of the overall yield from the taxes in question. In relation to the concerns expressed by the Deputies, I would emphasise again that the scheme is optional and traders can still opt for periodic payments if they wish to preserve their existing cash flow arrangements. Deputies can also rest assured that the Collector-General will closely monitor the scheme to guard against any abuses. In my view Deputies should focus on the positive elements of the scheme, namely, that it will reduce the administrative burden on certain small-scale traders and employers and will release more resources in Revenue to pursue evasion, default and better collection.

Is it agreed to let the Minister have an additional two minutes to compensate for the time taken from him at the beginning of his speech? Agreed.

Deputy Noonan had a few queries on section 16, the new legislation on the taxation of collective investment undertakings. The first point I want to make in reply is that such undertakings which are located in the International Financial Services Centre and in the Shannon customs-free zone, must be for the exclusive benefit of non-residents. No Irish tax charges will arise in respect of the income and capital gains of these undertakings. Undertakings located elsewhere in Ireland will also be free from income and capital gains tax. In so far as the income and gains of these undertakings are distributed to Irish residents, the Irish residents will be liable to tax on them and the withholding tax provisions will apply at the point of distribution. The withholding tax will also apply to the undistributed income of undertakings outside the financial centre and Shannon.

Deputy Noonan also referred to section 17, which is an anti-evasion provision in relation to Irish investors in foreign UCITS. Let me assure the Deputy that this section does not place any impediment in the way of the free movement of capital within the EC. But there are systems in place to monitor capital movements and we are going to use these — and any other mechanism available to us — to prevent tax evasion. I hope all sides of this House will support our efforts in this regard.

In regard to the clarification sought by Deputy Noonan on section 13, this is not a new measure. It is merely a technical amendment to put beyond doubt the intention that the maximum total of first-year capital allowances on farm buildings is to be 50 per cent, with the remaining 50 per cent of expenditure being written off at the rate of 10 per cent per annum. Last year's Finance Act introduced the maximum accelerated allowance of 50 per cent for farmers, as for every other category of taxpayer.

Deputy Noonan's concerns about the scope of section 20 are unfounded. The extension is very specific, and is limited to technical or consultancy services which are directly related to software development and data processing services and which have been grant-aided by the IDA. Other types of consultancy will not qualify and there is no difficulty in distinguishing between them.

In regard to the toll-roads provision in section 15, the previous relief of 50 per cent expired at end March. In order to encourage private sector investment and participation in toll-road developments, a full write-off of expenditure will now be allowed. It is intended, when the National Roads Authority is set up on a statutory basis, that it will be empowered to operate tolls on national roads and to enter into agreements with private interests whereby those interests would be remunerated from tolls on the road in return for their financial contribution to all or part of the construction costs of the road.

In conclusion I would again like to thank Deputies for their contributions and I look forward to the discussion on the individual sections of the Bill on Committee Stage.

As it is now 5 o'clock I am required to put the following question in accordance with an order of the Dáil of 18 April: "That in the case of the Finance Bill, 1989, and of Motion 8 for a Financial Resolution moved on 25 January, the Bill is hereby read a Second Time and the motion is hereby agreed to."

Will the Deputies who are demanding a division please rise in their places?

Deputies De Rossa, Gregory, Kemmy, McCartan and Mac Giolla rose.

As fewer than ten Members have risen in their places I declare the question carried and the names of the Deputies who claimed a division will be recorded in the Journal of Proceedings.

Question declared carried.

When is it proposed to take Committee Stage of this Bill?

On 9 May, subject to agreement.

Committee Stage ordered for Tuesday, 9 May 1989.
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