You never can tell. Taken as a whole, I think that my suggestions, if they would not bring in more revenue this year, might bring in more revenue eventually. I propose, roughly, to divide my argument in favour of this motion into two parts. The first part will be a plea for a complete revision of income tax law and practice which would, probably, take a year or two, at least, and the second part will deal with various matters which I consider require urgent adjustment and which I believe could be dealt with without any fundamental change in the present law and practice.
A very large number of citizens regard income-tax law and practice as something so difficult and so mysterious as to be beyond the understanding of the ordinary person, and that it must be left to the trained specialists. This point of view is understandable, but I do not share it, and I feel that it would be a good thing if it were studied more carefully, especially by those engaged in business. It is not easy adequately to define "income-tax" as we know it at present. It is an annual tax and is generally supposed to be a tax on the annual income received by the taxpayer, but it is also chargeable on amounts which the taxpayer does not actually receive, but which he is deemed by law to have received.
The British Income-tax Act of 1918 still remains the principal Act dealing with income-tax in Eire. It is a consolidation of earlier British Acts, and contains the rules for the assessment of tax under a number of heads or schedules as they are called. Various amendments have been made by British Finance Acts prior to 1922, and by Irish Finance Acts since then, but the Act of 1918 still remains the Principal Act. It is an Act which, according to my legal friends, has proved extraordinarily difficult to interpret, and it cannot be assumed that the same word is used in any two places with exactly the same meaning. Its interpretation depends to a considerable extent on a large number of reported cases, and a student of income-tax law has to spend a lot of time in the study of case law. In addition there has grown up what is known as income-tax "practice," which is controlled and regulated by the Revenue Commissioners.
Different methods of assessing the tax are applied according to the source from which the income is derived. The financial year is from April 6th in one year to April 5th in the next, and in general the tax payable for the financial year is assessed on the income of the preceding financial year. But there are quite a number of exceptions which are often rather bewildering to the ordinary taxpayer.
One of those, to which I will refer later, is the case of new businesses, employments and professions. The current year instead of the previous year is the basis of assessment for income from interest, annuities and dividends which are taxed at source, and also for income deemed to arise from the ownership of houses and lands charged under Schedule. "A" or deemed to arise from the occupation of lands for husbandry and charged under Schedule "B".
I want to suggest to the House and to the Government that the time has come when we should take steps to plan a system of taxation on personal income and on profits of trade, whether agricultural, industrial, or distributive. which has been devised to suit our own needs and the special conditions operating in this country. Although we may have much respect for the traditions which lie behind our present taxing system, we cannot ignore the fact that it was devised largely for conditions in another country and that very great changes have taken place in this country since the Principal Act was passed 27 years ago.
A leading accountant told me a short time ago that the present system, before it had all the complexities of corporation profits tax, excess corporation profits tax, excess surtax and children's allowances tagged on to it, was on the whole not too difficult. What may be not too difficult for an expert may be, none the less, very difficult for the ordinary man or woman who has to pay the tax. I suggest the appointment of a commission which would be asked to recommend a system of taxation on personal income and on business profits which would suit Irish conditions and which would give a total yield similar to that obtained at present from income-tax and corporation profits tax. The commission should be asked to consider whether it would be practicable to differentiate between the profits which go simply to add to the private wealth of individuals and profits which go to the development of trade or industry in this country which will increase employment so that the former may be taxed at a higher rate than the latter.
One of the first questions to be considered by such a commission would be that of general simplification. It is, I think, a principle of just and equitable taxation that it should be as easy as possible for the taxpayer to ascertain his actual liability. This is particularly so in the case of a tax payable on income. A great deal of misery has been caused by persons spending or undertaking liabilities in excess of their income. This is not infrequently the result of a belief that their income-liability is less than it actually is. Every person with a taxable income, except where the tax is deducted at source, should lay aside sufficient to meet his tax when it becomes due. How can he do so accurately if he does not know the amount? A person with a large income in excess of his needs can easily save enough to meet any eventualities, but by far the larger number of income-tax payers find it difficult enough to make ends meet after providing for their essential needs and those of their dependents.
A similar argument may be used in relation to the profits of a company, the main difference being that the tax payable by a company is often more difficult to ascertain. This is especially so since the last Budget. A company should provide for its income-tax and corporation profits tax before paying a dividend or embarking on expenditure on improvement or for the purpose of business extension. It is very unsatisfactory if it has to wait a year or more before ascertaining its liability. I do not think that a commission would have any great difficulty in making proposals which would simplify income-tax so far as the ordinary individual is concerned.
My first suggestion in that direction would be that all income-tax payable by individuals should be assessed on the income actually received by the taxpayer during a period of 12 calendar months. I would prefer that period to be January 1st to December 31st in every year, but the exact dates are not very important. It is comparatively easy for the average individual to estimate the income he is likely to receive in any 12 months, deduct the well-recognised allowances and lay aside from his income enough to pay the tax, when due. There is a great deal to be said for the "pay as you earn" system recently introduced into Great Britain as a war measure, and I am inclined to think that it has come to stay in that country, and may even be extended in its scope. It was not popular at first amongst employers, but I have been told that, in practice, they have not found it as difficult as they anticipated. Personally, I have no idea whether or not it would be practicable to introduce some similar plan here but, if it were, it is a matter well worth consideration. It is not so popular amongst the taxpayers, because it has succeeded in getting in more taxes, but, for that reason, it might be popular with the Minister.
The next suggestion that I would like to make is that an effort should be made to set out in an Act exactly what is "income" for income-tax purposes. This is not, I think, to be found in any Act or even in a collection of Acts, and I may be told by the Minister that I am asking for the moon. I find it difficult, however, to see how any real simplification can take place without some serious effort to provide a statutory definition of "income" for tax purposes.
I am also strongly of the opinion that there ought to be a change in the method of assessment of new and discontinuing businesses, employments and professions. This would not, I be lieve, cause any administrative difficulty, if all assessments on individuals were assessed on the actual income received or deemed to have been received in a financial year. At present, I am satisfied that it causes a certain amount of unfairness, with consequent dissatisfaction. An employee who receives an increase in remuneration in any year will in most cases pay his tax in that year on the previous year's income, but if by any chance the increase of remuneration carries with it some element of promotion, especially if his work is called by a new name he may find that he is assessed on his actual year's income. Thus, two employees in the same business may be treated differently although both may receive exactly the same increase, the reason being that one is regarded as having a new source of income and the other not. It also works in an unsatisfactory manner in relation to fees payable to directors which are voted at an annual meeting of a company held usually months after the end of the trading year. A small director's fee is often split up and taxed as for two earlier "financial" years by means of additional assessments with a consequent adjustment of surtax if payable. This causes a certain amount of trouble both to the tax authorities and to the taxpayer, which appears to me to be unnecessary. Why not charge the tax on directors' fees in the year in which the fee is actually received?
In my opinion Schedule A taxation also requires revision. As it stands at present it is inequitable as a tax on income. If the taxpayer receives his income from rents, I do not see why he should not pay on his actual income after deducting all expenses necessary to the maintenance of the property. It is, however, when Schedule A tax is levied on the person who occupies his own house that it appears to me to operate most unfairly.
One man I know paid £2,000 for a modern house valued at £40. Another paid approximately the same sum for an old house with a valuation of £80. The latter has to pay twice the income-tax that the former has to pay. Both expended the same amount of money, and I think in equity should pay the same tax if it is to be regarded as income-tax. It is well known that the valuation of a house is not a guide to its market value. For reasons, which I have never been able to understand, a Fianna Fáil Government decided to charge income-tax on five-fourths of the valuation, thereby increasing the inequalities which exist.
Another subject which seems to me to require examination is the system under which repairs to buildings used for business purposes are allowed as an expense but new buildings are regarded as capital expenditure. I have no quarrel with the allowances made for repairs to business premises which are usually measured on a reasonable basis. In normal times every encouragement is given to companies to keep their premises in good repair. It seems to me, however, that it would be in the public interest to encourage new building, especially in cities or towns where there is a very large number of very old buildings. It is desirable that our cities should be gradually rebuilt and it would be good policy to encourage privately-owned companies to do this work. At present there is a very great temptation to keep on repairing old buildings as long as they will stand and in many cases the money spent on repairs over a number of years would have paid for a new and up-to-date building. It seems to me that it would be wise to allow for the amortisation of sums spent on new buildings which replace old ones over a period of say 50 years. This may not be an urgent question as supplies will probably not be available for an extensive replacement of old business premises for several years. I think, however, it should be carefully considered in the near future.
I now turn to the method of taxing business profits in which I consider that there is the greatest need for change, in order to meet Irish conditions. It has seemed to me for a long time that there ought to be a clear distinction between the tax payable on the income of individuals and the tax payable on profits of a trade or industry which are not paid out to any individual by way of salary, fees, dividends or share of profits.
All taxes paid by a company engaged in business, whether that business be the production of some commodity or distribution to the consumer, are part of the costs of the operation of the business. The tax will be passed on to the consumer, if this can be done, with the result that it is spread over all the customers of the business. In some cases, where a company carries on both home and export trade, the tax can only be passed on to the home customer, as any attempt to increase the export prices would simply kill the trade. In other cases, where there is no protection and a highly competitive market, it is impossible to pass on the tax. Where the tax cannot be wholly or partially passed on, the financial position of the concern may be weakened, and it will probably find it difficult to provide adequate reserves for depreciation, and will certainly be unable to lay aside profits for use in future development.
In this connection it is essential to bear in mind that income-tax is payable by a company, not on its real profits as they would be measured on a normal commercial basis, but on its "assessable" profits which is often a very different thing indeed. I admit that it is not always easy to say what are the real profits of a company. As a general rule, however, I think it may be said that the real profit in any year is the balance of the income over expenditure after provision has been made for annual depreciation, and for the amortisation of all money spent on assets which will be used up in the making of profits.
If a company fails to make adequate provision for wasting assets and pays out annually, whether in profit distribution or in taxation, more than it can properly afford to do, it will reduce the value of its capital assets, and will sooner or later find itself in financial difficulties. No well-managed company would be satisfied to confine its reserves to the amount allowed for wear and tear for the purpose of income-tax assessment. On every sum placed to reserve in excess of the standard rates of wear and tear, the State forces the company to pay 8/9 in the £ (not including excess corporation profits tax). In small companies with an assessable profit of £2,500 or less the amount is only 7/6. This seriously reduces the total that can be placed to reserve, to the detriment of many of our industries.
The stated policy of the Government is industrial and agricultural efficiency. We plan not only to supply, as far as practicable, the needs of our own people but also to export our products. The Government says that it is determined to reduce the cost of living after the war. I am convinced that it will fail in all these aims if it fails to realise that present taxation on productive effort is too high. The public generally believes that trade and industry, which has not made excess profits, pays 7/6 income-tax on its profits plus 2/- corporation profits tax on the profits in excess of £2,500. This works out at approximately 43¾ per cent. which, having regard to present high taxation, would not seem unreasonable if it were true. Actually the tax payable is at a much higher rate, and I believe that if figures were available to show the average percentage of real profits paid out in tax, the public generally would recognise that industry is too highly taxed for a country which has only commenced to develop its industrial resources. My contention is that income tax law should be revised to provide for the measurement of business profits as near as practicable to true profits. If and when this is done, the Finance Minister will have to consider what tax he desires to impose. He will then be able to decide to what extent he considers it wise to take business profits for the State, but whatever percentage he demands he will know that it is a percentage of real profits. At the present time I do not think he does know what percentage of real profits he is taking.
As I have already indicated, I think that the time has come when the State should make a clear distinction between income which goes into the pockets of individuals and profits which are available for increasing the efficiency of our agriculture and our industry—which will increase employment and reduce the cost of the home-produced commodity. The money made by a company may roughly be divided into two parts, one part which is paid to individuals whether as salaries, wages, fees or the distribution of profits. The other part is retained in the business. At present the State taxes the first part more lightly than the second part. Both income tax and corporation profits tax are payable on the second part. It is almost an encouragement to pay out money in salaries or dividends, rather than retain it in the business. True, of course, there is a surtax on high incomes, but the proportion of surtax payers at the rate of 2/- in the £ (which is the rate of corporation profits tax) is relatively small.
It seems to me that it would be wise national policy to encourage the keeping of profits in a business, as in the vast majority of cases this would gradually lead to a higher profit in the future with a greater yield to the State, and I think it would be wise to discourage the paying out of too much profit to individuals. In particular, I think that expenditure on research and development should receive definite encouragement.
I would very much like to see these problems considered by a commission consisting of experienced men. Personally, I would favour the ultimate abolition of the British system of income-tax under which we work at present, and the substitution of two separate and distinct taxes, one an income-tax on the personal income which would be more or less on the lines of the present income-tax, and the other, a tax on trading profits which would be an entirely new tax and based on the amount which the State could take from industry or agriculture without injuring their efficiency, or their ability to give employment.
I do not claim to be an expert, but I do know enough to realise that my proposal is not a simple one and that many difficulties would have to be overcome. One of these is the taxation of business partnerships—another is the taxation of agricultural profits as distinct from the income of individuals engaged in agriculture. Another difficulty which would arise is that of the taxation of capital appreciation which is exempt at present. If profits retained in a business are taxed at a lower rate, it would almost certainly lead in come cases to an increase in the value of the capital which might be paid out to shareholders as bonus shares or in some other manner. As this would be, in effect, payment of profit to individuals, some tax would have to be charged on such distributions. Personally, I do not see why casual profits made on the stock exchange should not be taxed. If a man makes a few thousand pounds on Great Southern Railways or other shares the money he gets is just as good as that received by a salary or wage-earner, and I think the State is entitled to its share. Of course, if you tax profits made on the realisation of capital you must also allow losses if they occur from realisation.
There are many difficulties to be considered, but I do not think that they are unsurmountable. If you are really satisfied with our present system of income-tax, then, by all means, do nothing. If you admit that it requires change, then why not face up to it? We have tackled much greater problems in the last 20 years with a fair measure of success.
Before leaving this part of my subject, I would like to point out that I have not included excess corporation profits tax as a subject for consideration by a commission because I understand that the Minister for Finance does not intend to continue this tax after the war. To continue this tax in its present form, when the necessary supplies are available for increased trade, would be disastrous. It is not a tax on profiteering. It is a tax on any increased business over the pre-war standards. If a company had excessive profits before the war it can continue these excessive profits without paying any excess corporation profits tax. If a company had small profits or a small trade before 1939, it cannot better its position without paying 75 per cent. to the State. I am, therefore, assuming that the Minister will resist all temptation to continue this tax in its present form after the war is over.
If a commission is to be appointed, there should be no delay. I think the first years after the war may well be exceedingly difficult, especially for those engaged in industry. It would probably take a commission a year before a report could be prepared and probably another year before substantial changes could take effect.
I now turn to the second part of my subject, i.e., amendments to the present law which could be made without any drastic change in the general system of taxation. This applies to a greater or less degree to some of the suggestions I have made with regard to income-tax payable by individuals and I will not repeat them. There are, however, one or two other suggestions that I would make. I consider that the cost of travelling to and from the place of employment should be allowed as an expense deductible from income before tax is assessed. Very few people with low incomes can choose their place of residence freely—they have to live wherever they can find a house at a rent they can pay. Salaries and wages are becoming more and more standardised for the same work. An employee who lives miles from his work is usually paid the same as one who lives in the immediate neighbourhood, but his actual income is less. He cannot earn his salary unless he gets to his work, and the cost of getting there is an expense essential to the earning of his income.
It also seems to me that the allowance deductible for a child should operate from the date of birth instead of as at present in the first financial year after birth. There is very heavy expense when a child is born, and the allowance is required at once. This would cause a little trouble as assessments would have to be revised, but I think it would be worth the trouble.
The immediate changes which I would urge on the Minister for Finance mostly relate to the taxation of business profits. Pending the consideration of the larger questions which I have already dealt with, I think that some immediate steps should be taken which would somewhat case the situation in the early post-war period during which our industries may find themselves in a worse position than similar concerns in Great Britain or Northern Ireland, if no change is made. Sooner or later after the end of the war in Europe supplies of raw materials and fuel will improve, and it is of the utmost importance that our trade and industry should be in a position to meet the anticipated demands, and also provide the maximum possible employment.
In a letter to the Minister in November last, the Dublin Chamber of Commerce summed up the changes advocated by it as follows:—
"(1) An all-over addition, not less favourable than has been granted in Great Britain and Northern Ireland, to the standard rates of wear and tear of plant and machinery.
(2) The necessity of granting obsolescence allowance where replacement does not occur.
(3) Allowances, by way of depreciation or otherwise, in respect of those wasting assets used in commercial activities, for which no allowance whatever is made at present.
(4) Revision of the present allowance of one-sixth of the Schedule A assessment in respect of factory buildings (if leasehold, revision might take place under (3).
(5) More equitable treatment of development and research expenditure, whether of a "deferred revenue" or "capital" nature, the cost of which at present invariably falls entirely on the proprietors without any tax relief."
That is a quotation from a letter sent to the Minister and circulated to its members by the chamber of commerce. The chamber of commerce did not specifically refer to the position of companies who, because of the emergency, have been unable to carry out repairs which are essential to the running of the business. If these repairs could have been done they would have been allowed as an expense before computing income-tax, corporation profits tax, and excess corporation profits tax. The result is that many manufacturing companies have been assessed on fictitious profits, because they could not do essential repairs, and any reserves they made to provide for the carrying out of repairs after the emergency were not allowed for tax purposes.
It is well known that the war has made the proper repair of machinery and plant impossible in very many cases, and the repairs which are necessary have accumulated to an alarming degree. In some cases, companies have become liable to excess corporation profits tax which would not be so liable if they could have carried out adequate running repairs. In these cases the State has collected 75 per cent. of what are really fictitious profits. It may well be years after the war before the work can be done, and the Minister for Finance has more than once stated that excess corporation profits tax will not be continued after the emergency, so the companies may be unable to claim a refund of the excess corporation profits tax paid by them.
The remedy for the situation is, surely, to allow companies to receive allowance for taxation purposes for all accrued charges of this nature, supported by full evidence which it will be possible to supply in all genuine cases. The amount of all such allowances could be placed aside in the accounts of the companies concerned, and, if in any particular instances, it subsequently transpired that the whole amount of such allowances was not either utilised or required the unexpended portion could be brought back to taxation at the rates prevailing at the time when the allowances were made.
I do not think that administrative difficulties of any serious nature should arise in the working out of this arrangement. The Revenue Commissioners would retain full powers of satisfying themselves that the claims put forward are fully authenticated.
It is mainly with Great Britain that our manufacturers have to compete. To have any reasonable hope for the future, industries in this country must expect to be allowed to survive the emergency period on at least a level basis with British industries. Most British industries, owing to their participation in war production, must be keeping their plant and machinery at a fairly high level of efficiency, and in many cases they may come out of the present period better equipped than at the commencement. It has already been announced that the British Government is giving full consideration to all post-war questions of wear and tear, obsolescence, and other allowances requisite to the encouragement and maintenance of industrial concerns.
Irish industries will be faced with a very severe handicap, unless they are accorded at least as fair treatment in all matters of this kind, as compared with their British competitors, particularly as the only sound basis upon which Irish industry can be established must largely depend on its ability to compete as to efficiency and selling prices with industries of other countries operating under anything like comparable conditions.
Most of the other immediate changes which I would advocate relate to last year's Finance Bill which contained provisions which have caused a number of genuine hardships which, in all fairness, require to be remedied. The Minister was faithfully warned that these hardships and inequities would occur, both by members of the Oireachtas and by leading accountants, but he turned a deaf ear. Certain persons had found methods of legally evading corporation profits tax and excess corporation profits tax, and he was determined to catch them, no matter how many hardships he inflicted in so doing—like the Customs Bill, I suppose.
In particular, he made a special attack on subsidiary companies formed after May, 1941. I would have been in agreement with him as far as excess corporation profits tax is concerned if he had been fair as between all companies, but he took the extraordinary step of allowing subsidiary companies to get away with a considerable part of their excess profits if they happened to make up their accounts to a date prior to January 1st, 1944. This was, in my opinion, unfair. The provisions of Sections 13 and 14 of the Finance Act of 1944 should have come into force on a fixed date, with a provision that the profits arising in an accounting period which ended after the fixed date would be apportioned between the part of the accounting period which was prior to that date and the part subsequent to that date. This was the procedure adopted by the Minister when excess corporation profits tax was introduced and it was fair to all.
The Minister also introduced into last year's Finance Bill the principle of retrospective taxation to an extent, as far as I know, never done before. Companies which had already made their distributions based on the tax law as it stood at the time found that they were liable for tax which they could not have anticipated. This action was resented by every business man of my acquaintance. It has caused considerable uneasiness as to the future and has made it exceedingly difficult to plan ahead. Unless he makes it clear that he does not intend to continue the principle of retrospective taxation in future Finance Acts, I think the effect on our post-war development will be very bad.
I think the Minister should give some indication as to his attitude towards subsidiary companies which may be formed for the purpose of the extension of industry after the war. Does he intend to continue the provisions of the 1944 Act in relation to corporation profits tax after excess corporation profits tax has been discontinued? At present any person who is a shareholder in one company cannot invest money in a new company without running the risk that his doing so would cause the new company to be regarded as a subsidiary.
It also seems to me unfair that a company which is treated as a subsidiary and assessed jointly with the parent company for the purposes of corporation profits tax and excess corporation profits tax should be regarded as a new company for the purposes of income-tax. When a company divided up its trade by forming a subsidiary company, I can easily see why the Minister decided to treat the two companies as one for the purposes of excess profits taxation. To do so seemed to me to be fair except when the subsidiary company was formed to undertake new business not carried on previously by the parent company, but it was unfair to force such companies to pay, under the rules which apply to new companies, more income-tax than would have been paid if no subsidiary company had been formed. This requires reconsideration, and in my opinion, the Minister should clear up this position in the next Finance Bill and make special provisions for new companies formed to carry on new business even though they may be owned wholly or in part by existing companies or shareholders in existing companies.
There is another matter in which I profoundly differ from the attitude of the Government. The Government shows its disapproval of employees becoming directors of companies in which they are employed and taking shares in such companies, by adding to the taxation of companies which permit this to occur. I can understand the reasons for this action as regards excess profits taxation, though I believe a better method could have been found which would achieve a similar result. But the Minister has not confined these provisions to excess corporation profits tax. They apply also to corporation profits tax which is likely to continue after the war. In my opinion, it is good that directors and managing directors should, where practicable, be appointed from the staffs of companies engaged in trade or industry, and that they should invest their savings in the businesses in which they work. I therefore urge an amendment of the corporation profits tax provisions which are a bar to such action. The provision that if a whole-time managing director owns more than 5 per cent. of the ordinary share capital the company must pay corporation profits tax on his salary in excess of £1,000 is unjustifiable and should be amended, especially in cases which are fairly common where a company is controlled by one person who owns more than half of the ordinary shares or who is a "governing director". It being, therefore, clear that the director with his 5 per cent. would not have control of the company.
Section 15 of the Finance Act of 1944 contains what I consider to be a very bad principle. It gives autocratic powers to the Revenue Commissioners and makes it possible for them to disallow in tax computations expenditure which has been made by companies in the course of business. They could, for instance, object to the appointment of a managing director or other employee on the grounds that the additional expense would avoid or reduce liability for corporation profits tax. They could object to any increase of remuneration to an individual or other expenditure of any kind which would reduce liability to tax. If this autocratic section had been confined to excess corporation profits tax and limited to the duration of the war, I would not be inclined to quarrel with it, as I recognise fully that it is very difficult to cover in an Act every possible method of evasion of excess profits taxation. But it applies to corporation profits tax and is apparently intended as a permanent piece of legislation. I am sure that the Revenue Commissioners, to the best of their ability, will operate it fairly as between different companies and I am sure that they intend to act reasonably after due consideration. But it is to my mind none the less a bad principle and it will make it more difficult for a company to estimate its tax liability. It seems to me that this section when added to the danger of retrospective taxation will force companies to delay for a year or two before using any profits for business extension or improvement of any kind. This will certainly not help the Minister for Industry and Commerce in his plans for post-war development.
I have been informed by several leading accountants that quite a number of cases of real hardship have already arisen under the provisions of the 1944 Finance Act. There has been considerable delay in the making of assessments and the effect of the Act is only now being realised, and unless the Minister takes steps to rectify the serious hardships which have arisen there will be pretty widespread dissatisfaction, especially in the case of companies which had no pre-war trade year and which are very adversely affected by Section 13, paragraph (1) (c) of the 1944 Act. When that Act was before the Oireachtas last year, the Minister showed an unusual unwillingness to pay attention to representations which were made to him. He is now one year older and I hope will see the error of his ways and act accordingly.
Although no one likes high taxation, I think the average person feels no resentment if he feels that the taxation is fair as between all taxpayers in similar circumstances — when individuals or companies feel that they are inequitably treated there is strong resentment, and I know that this exists at the present time.
This is a very large and important subject, and I have by no means exhausted the matters which I might have dealt with. I hope, however, I have said enough to commend the resolution to the House and to provide subject matter for discussion.
I have deliberately avoided dealing with income-tax in relation to agricultural profits, because I have no practical experience and because there are many members of this House very well qualified to deal with agricultural problems. I have made no reference to the amendment in the name of Senator Sir John Keane, because I am not competent to deal with it. It is, of course, a matter for the House whether or not it should be embodied in the resolution.
