Select Committee on Finance and General Affairs debate -
Tuesday, 25 May 1993

SECTION 13.

Mr. Yates

I move amendment No. 61:

In page 47, subsection (1), to delete lines 46 to 48 and substitute the following:

"13.—(1) An individual shall not at the same time have a beneficial interest in investments exceeding £50,000 between aggregated investments in the following classes of investment.".

This is a straightforward amendment. Section 13, at the bottom of page 47 of the Bill, sets out a limit for any individual of £50,000 in total in the four different 10 per cent DIRT special classes of investment. It transpires however, that one has to divide one's money between just two of the classes of investment and, I believe, couples are also limited to two special classes. I want that opened up so that one can divide one's money between investment classes — for example, £12,500 in one, £15,000 in another and so on. In other words, there would be a total spread available to the investor between the four classes, but investment in them would still be subject to the ceiling of £50,000.

I am proposing to insert at the top of section 13 the following sentence: "An individual shall not at the same time have a beneficial interest in investments exceeding £50,000 between aggregated investments in the following classes of investment". That would allow people the flexibility to spread their investments around. Obviously, one difficulty is that if people already have special savings accounts they may wish to keep their money in those. The change would, however, put the special investment classes on a par, making them all more attractive and introducing greater flexibility. I believe this is a reasonable provision.

Sitting suspended at 4.45 p.m. and resumed at 5.10 p.m.

Mr. Yates

There should be flexibility to put money in each of the investment products in any amount as long as the aggregate does not exceed £50,000.

Mr. B. Ahern

The issue is to try to regulate the system. There is considerable flexibility in some of the schemes. For an individual who is not saving but investing jointly with his or her spouse the limit is £50,000 in any one saving or investment product, or £25,000 in each of two products, one of which must be special savings. For an individual investing jointly with his or her spouse the limit is £50,000 and two products, both of which may be of the same type. If they are not of the same type, one must be a special savings account. That provides flexibility.

There are two difficulties with going up and down and breaking the amounts. We are hopeful that taxpayers, by sticking to simple rules, will help to ensure that there is compliance concerning people with not over £50,000 and that the banks can do so equally. If, however, the amounts are split willy nilly, it is far more difficult to do that. The question then arises of how to spread each individual's £50,000 entitlement between the special savings account and the new special investment products to be offered by life assurance companies, unit trusts or designated brokers. The obvious answer is to allow each individual to take up whatever combination of special savings and investment products he or she chooses, and I think this is Deputy Yates' point, as long as his or her total take up does not exceed £50,000.

Ideally, I would wish to be able to allow savers and investors such an unrestricted choice, but the reality is that such an approach would only be adopted at the cost of abandoning the operation of any limits by the financial institutions involved. For example, if a bank knows that an individual is not to have more than £50,000 or £25,000 in his or her special savings account, it can ensure that no more than those amounts apply to an individual's account at any time. It would be unrealistic to expect the banks to operate a different limit for each special savings account holder, besides which it would be almost impossible to administer effectively. So, while I would like to allow flexibility in working out schemes with the banking and the other institutions I have mentioned, it is not possible to operate that flexibility because, undoubtedly, it would increase the temptation for individuals to exceed their entitlements and would become inoperable because the banks could not police them.

Amendment No. 61, by leave, withdrawn.

Section 13 agreed to.

NEW SECTION.

Chairman

Amendments Nos. 62 to 65, inclusive, form a composite proposal so it is proposed to take them together. Is that agreed? Agreed.

Mr. B. Ahern

I move amendment No. 62:

In page 50, before section 14, to insert the following new section:

14.—(1) (a) In this section and section 15*—

"chargeable period" means an accounting period of an undertaking for collective investment which is a company or, as respects such an undertaking which is not a company, a year of assessment;

"designated assets" means—

(i) land, or

(ii) shares in a company resident in the State which are not shares—

(I) listed in the official list, or

(II) dealt in on the smaller companies market, or the unlisted securities market,

of the Irish Stock Exchange;

"designated undertaking for collective investment" means an undertaking for collective investment which, on the 25th day of May, 1993, owned designated assets for which it gave consideration (determined in accordance with section 9 of the Capital Gains Tax Act, 1975) the aggregate of which is not less than 80 per cent. of the aggregate of the consideration (as so determined) which it gave for the total assets it owned at that date;

"distribution" has the same meaning as it has for the purposes of the Corporation Tax Acts;

"guaranteed undertaking for collective investment" means an undertaking for collective investment all of the issued units of which, on the 25th day of May, 1993, are units in respect of each of which the undertaking will make one payment only, being a payment—

(i) to be made on a specified date in cancellation of those units, and

(ii) which is the aggregate of—

(I) a fixed amount, and

(II) an amount, which may be nil, determined by a stock exchange index or indices;

"relevant Regulations" means the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations, 1989 (S.I. No. 78 of 1989);

"undertaking for collective investment", subject to paragraph (b), means—

(i) a unit trust scheme, other than—

(I) a special investment scheme within the meaning of section 10, or

(II) a unit trust mentioned in section 31 (4) of the Capital Gains Tax Act, 1975,

which is, or is deemed to be, an authorised unit trust scheme within the meaning of the Unit Trust Act, 1990, and which has not had its authorisation under that Act revoked,

(ii) any other undertaking which is an undertaking for collective investment in transferable securities within the meaning of the relevant Regulations, being an undertaking which holds an authorisation issued pursuant to the relevant Regulations and that authorisation has not been revoked, or

(iii) any authorised investment company within the meaning of Part XIII of the Companies Act, 1990, which—

(I) has not had its authorisation under that Part of the said Act revoked, and

(II) has been designated in that authorisation as an investment company which may raise capital by promoting the sale of its shares to the public and has not ceased to be so designated,

which is neither an offshore fund within the meaning of section 65 (1) of the Finance Act, 1990, nor a specified collective investment undertaking within the meaning of section 18 (as amended by this Act) of the Finance Act, 1989;

"unit" includes a share and any other instrument granting an entitlement—

(i) to a share of the investments or relevant profits of, or

(ii) to receive a distribution from, an undertaking for collective investment;

"unit holder" means, in relation to an undertaking for collective investment, any person who by reason of the holding of a unit, or under the terms of a unit, in the undertaking is entitled to a share of any of the investments or relevant profits of, or to receive a distribution from, the undertaking;

"standard rate" has the meaning assigned to it by section 1 (1) of the Income Tax Act, 1967;

"standard rate per cent." has the meaning assigned to it by section 155 (5) of the Corporation Tax Act, 1976;

(b) For the purposes of this section and section 15*, references to an undertaking for collective investment in those sections, other than in this paragraph, shall be construed so as to include a reference to a trustee, management company or other such person who—

(i) is authorised to act on behalf, or for the purposes, of the undertaking, and

(ii) habitually does so,

to the extent that such construction brings into account for the said purposes any matter relating to the undertaking, being a matter which would not otherwise be brought into account for those purposes.

(c) For the purposes of this section—

(i) as respects an undertaking for collective investment which is a company, where an accounting period of the company begins before the 6th day of April, 1994, and ends on or after that day, it shall be divided into two parts, one beginning on the day on which the accounting period begins and ending on the 5th day of April, 1994, and the other beginning on the 6th day of April, 1994, and ending on the day on which the accounting period ends, and both parts shall be treated as if they were separate accounting periods of the company, and

(ii) without prejudice to the provisions of section 29 (2) of the Finance Act, 1984, any attribution of income or chargeable gains of such an undertaking to periods treated as separate accounting periods by virtue of subparagraph (i) shall be made—

(I) as respects such income, on the basis of the time that income arises to the undertaking, and

(II) as respects such capital gains, on the basis of the time of disposal of the assets concerned,

and section 155 (13) of the Corporation Tax Act, 1976, shall not have effect for the purpose of such attribution.

(2) (a) Other than in the case of subsections (7) to (9) of section 18 (as amended by this Act) of the Finance Act, 1989, that section shall not apply, and the following provisions of this section shall apply, to an undertaking for collective investment as respects the chargeable periods of the undertaking ending on or after—

(i) the 6th day of April, 1994, if the undertaking was carrying on a collective investment business on the 25th day of May, 1993, or

(ii) the 25th day of May, 1993, if the undertaking was not carrying on such a business at that date.

(b) As respects an undertaking for collective investment which is a company, the corporation tax which is chargeable on its profits on which corporation tax falls finally to be borne for a chargeable period shall be reduced, for all the purposes of the Tax Acts, so that, before it is reduced by any credit, relief or other reduction under those Acts (other than under this section), it is the standard rate, for the year of assessment in which the chargeable period falls, of those profits:

Provided that, for the purposes of the foregoing provision of this paragraph, where part of the chargeable period falls in one year of assessment (referred to hereafter in this proviso as the "first-mentioned year of assessment") and the other part falls in the year of assessment succeeding the first-mentioned year of assessment and different standard rates are in force for each of those years, "the standard rate" shall be deemed to be a rate per cent. calculated by the formula—

(A × C)		(B × D)
———	+	———
E		E

where—

A is the standard rate per cent. in force for the first-mentioned year of assessment,

B is the standard rate per cent. in force for the year of assessment succeeding the first-mentioned year of assessment,

C is the length of that part of the chargeable period falling in the first-mentioned year of assessment,

D is the length of that part of the chargeable period falling in the year of assessment succeeding the first-mentioned year of assessment, and

E is the length of the chargeable period.

(c) As respects an undertaking for collective investment which is not a company—

(i) the capital gains tax which is chargeable on the chargeable gains accruing in a year of assessment to the undertaking shall be reduced so that the amount of such tax, before it is reduced by any credit, relief or other deduction under any provision, other than under this section, of the Tax Acts or the Capital Gains Tax Acts, is the standard rate, for the year of assessment, of the chargeable gains accruing to the undertaking, and

(ii) only so much of income arising or gains accruing to the undertaking shall be chargeable to income tax or capital gains tax, as the case may be, as is, or is to be—

(I) paid to, or

(II) accumulated or invested for the benefit of,

unit holders in the undertaking or as would be so paid, accumulated or invested if any gains accruing to the scheme by virtue of subsection (4) were gains on an actual disposal of the assets concerned.

(3) (a) (i) Section 2 of the Corporation Tax Act, 1976, shall not have effect as respects a distribution received by an undertaking for collective investment which is a company; and the income represented by the distribution shall be equal to the aggregate of the distribution and the amount of the tax credit in respect of the distribution.

(ii) Where an undertaking for collective investment which is a company is entitled to a tax credit in respect of a distribution which is chargeable, by virtue of subparagraph (i), to corporation tax—

(I) it may set the credit against the corporation tax, as reduced by virtue of subsection (2) (b), chargeable on its profits for the chargeable period in which the distribution is made and, where the credit exceeds that corporation tax, the excess shall be paid to it, and

(II) notwithstanding the provisions of sections 24 and 155 of the Corporation Tax Act, 1976, the income represented by the distribution shall not be franked investment income for the purposes of sections 15 and 25 of that Act.

(b) Where a company resident in the State makes a distribution to an undertaking for collective investment which is not a company, the tax credit, if any, attaching to the distribution shall be set against—

(i) the income tax chargeable in respect of income arising to, or

(ii) the capital gains tax, as reduced by subsection (2) (c) (i), chargeable in respect of chargeable gains accruing to,

the undertaking for the year of assessment in which the distribution is made and—

(I) where the credit exceeds the aggregate of that income tax and capital gains tax, the excess shall be paid to the undertaking, and

(II) a payment shall not be made, in respect of the credit, under section 88 (4) of the Corporation Tax Act, 1976.

(c) Notwithstanding any provision of that Chapter, Chapter IV of Part I of the Finance Act, 1986, shall apply to a deposit, within the meaning of the Chapter, which is for the time being beneficially owned by an undertaking for collective investment which is not a company as if such a deposit were not a relevant deposit, within the meaning of the Chapter.

(4) (a) Every asset (other than assets to which subsection (5) (a) (ii) relates) of an undertaking for collective investment on the day on which a chargeable period of the undertaking ends shall, subject to the subsequent provisions of this subsection, be deemed to have been disposed of and immediately reacquired by the undertaking at the asset's market value on the said day.

(b) Subject to paragraphs (c) and (d), chargeable gains or allowable losses, which would otherwise accrue to an undertaking for collective investment on disposals deemed by virtue of paragraph (a) to have been made in a chargeable period (other than a period in which the collective investment business of the undertaking concerned ceases) of the undertaking, shall be treated, subject to subparagraphs (ii) and (iii), as not accruing to it, and instead—

(i) there shall be ascertained the difference (hereafter in this subsection referred to as "the net amount") between the aggregate of those gains and the aggregate of those losses, and

(ii) one-seventh of the net amount shall be treated as a chargeable gain or, where it represents an excess of losses over gains, as an allowable loss accruing to the undertaking on disposals of assets deemed to be made in the chargeable period, and

(iii) a further one-seventh shall be treated as a chargeable gain or, as the case may be, as an allowable loss accruing on disposals of assets deemed to be made in each succeeding chargeable period until the whole amount has been accounted for.

(c) For any chargeable period of less than one year, the fraction of one-seventh referred to in paragraph (b) (iii) shall be proportionately reduced; and where this paragraph has had effect, in relation to any chargeable period before the last such period for which paragraph (b) (iii) applies, the fraction treated as accruing in that last chargeable period shall be reduced so as to secure that no more than the whole of the net amount has been accounted for.

(d) Where the collective investment business of the undertaking concerned ceases before the beginning of the last of the chargeable periods for which paragraph (b) (iii) would apply in relation to a net amount, the fraction of that amount that is treated as accruing in the chargeable period in which the business ceases shall be such as to secure that the whole of the net amount has been accounted for.

(5) Notwithstanding any provision of the Capital Gains Tax Acts, for the purposes of computing chargeable gains accruing to an undertaking for collective investment—

(a) (i) section 3 of the Capital Gains Tax (Amendment) Act, 1978, and

(ii) section 19 of the Capital Gains Tax Act, 1975, as it applies to assets specified in that section or in any other provision of the Capital Gains Tax Acts,

shall not have effect, and

(b) if the undertaking was carrying on a collective investment business on the 25th day of May, 1993, it shall be deemed to have acquired each of the assets it holds on the 5th day of April, 1994, apart from assets referred to in paragraph (a) (ii), at the asset's market value at that date.

(6) Subject to subsection (4) (b), where an undertaking for collective investment incurs allowable losses on disposals or deemed disposals of assets in a chargeable period, the amount (if any) by which the aggregate of such allowable losses exceeds the aggregate of chargeable gains on such disposals in the chargeable period, shall—

(a) be disregarded for the purposes of subsection (1) of section 5 of the Capital Gains Tax Act, 1975,

(b) be treated as reducing the income chargeable to income tax or corporation tax arising to the undertaking in that chargeable period, and

(c) to the extent that it is not treated as reducing income arising to the undertaking in the said chargeable period, be treated, for the purposes of the Capital Gains Tax Acts and this subsection, as an allowable loss incurred on a disposal of an asset deemed to be made in the next subsequent chargeable period.

(7) Notwithstanding any provision of the Tax Acts or the Capital Gains Tax Acts, unit holders in an undertaking for collective investment shall not be entitled to any credit for, or repayment of, any income tax, capital gains tax, or corporation tax paid in respect of income arising to, capital gains accruing to or profits of the undertaking.

(8) Notwithstanding subsection (2), the provisions of this section (other than this subsection) and section 15* shall be construed and have effect as respects designated undertakings for collective investment and guaranteed undertakings for collective investment as if—

(a) every reference therein to the 5th day of April, 1994, were a reference to the 5th day of April, 1998, and

(b) every reference therein to the 6th day of April, 1994, were a reference to the 6th day of April, 1998,

and, as respects such an undertaking, those provisions shall not have effect except as so construed:

Provided that—

(i) if the aggregate of the consideration (determined in accordance with section 9 of the Capital Gains Tax Act, 1975) given for the designated assets owned, at any time after the 25th day of May, 1993, and before the 5th day of April, 1997, by a designated undertaking for collective investment is less than 80 per cent. of the aggregate of the consideration (as so determined) given for the total assets owned by the undertaking at that time, or

(ii) if at any time before the 5th day of April, 1997, a guaranteed undertaking for collective investment makes any payment to unit holders in the undertaking which is not a payment in cancellation of those units,

this subsection (other than this proviso) shall have effect and be construed as respects that undertaking as if—

(I) each reference therein to the 5th day of April, 1998, were a reference to the 5th day of April, and

(II) each reference therein to the 6th day of April, 1988, were a reference to the 6th day of April,

next subsequent to that said time.".

Mr. Cox

I do not want to cause delay because we have to get through other issues. This is an eight-page amendment and I do not want the Minister to provide an eight-page technical explanation, but could we hear in plain English what is the thinking behind this new amendment that has been added in the past 48 hours?

Mr. B. Ahern

Deputy Cox is right. It is a long amendment and it introduces a new taxation regime for authorised unit trusts. undertakings for collective investments and transferable securities and authorised investment companies. The amendment deals with those savings and investment institutions which are not covered by last year's provisions which dealt with banks and building societies and this year's provisions in relation to life assurance companies. The essence of the new regime is a switch from a deferred liability, ultimately paid by the unit holder, to an annual liability paid at source by the unit trust. Taxation at source improves the efficiency of collection of the tax concerned by centralising its payments through the unit trusts. In addition, it puts the taxation of investment through unit trusts on a par with the taxation of savings and investments with banks, building societies and life assurance companies.

Amendment agreed to.

NEW SECTION.

Mr. B. Ahern

I move amendment No. 63:

In page 50, before section 14, to insert the following new section:

15.—(1) Subject to subsection (4), any payment made on or after the 6th day of April, 1994, in money or money's worth, to a unit holder by an undertaking for collective investment by reason of rights conferred on the holder as a result of holding units in the undertaking, shall not be reckoned in computing—

(a) total income for the purposes of the Income Tax Acts, or

(b) total income brought into charge to corporation tax for the purposes of the Corporation Tax Acts,

of the holder.

(2) Subject to subsections (3) and (4), as respects a disposal on or after the 6th day of April, 1994, of units in an undertaking for collective investment—

(a) no chargeable gain shall accrue on the disposal if the person disposing of the units acquired them on or after that date, and

(b) if the person disposing of the units acquired them before that date the chargeable gains on the disposal shall be computed as if—

(i) the consideration for the disposal were the market value of the units on the 5th day of April, 1994:

Provided that subparagraph (i) shall not apply in relation to the disposal of units—

(I) if, as a consequence of the application of subparagraph (i), a gain would accrue on that disposal to the person making the disposal and either a smaller gain or loss would so accrue if the paragraph did not apply, or

(II) if, as a consequence of the application of subparagraph (i), a loss would so accrue and either a smaller loss or a gain would accrue if the paragraph did not apply,

and, accordingly, in a case to which paragraph (I) or (II) of this proviso applies, the amount of the gain or loss accruing on the disposal shall be computed without regard to the provisions of subparagraph (i) (other than this proviso) but, in a case where this proviso would otherwise substitute a loss for a gain or a gain for a loss, it shall be assumed, in relation to the disposal, that the units were acquired by the person disposing of them for a consideration such that neither a gain nor a loss accrued to him on making the disposal,

and

(ii) for the purposes of selecting the appropriate multiplier (within the meaning of section 3 of the Capital Gains Tax (Amendment) Act, 1978), the disposal were made in the year 1993-94,

and, for the purposes of this subsection, references to units shall be construed as including a reference to an interest in units and the provisions of the subsection shall have effect, with any necessary modification, accordingly.

(3) (a) Where a person disposing of units in an undertaking for collective investment acquired them—

(i) on or after the 6th day of April, 1994, and

(ii) in such circumstances that by virtue of any enactment other than section 3 (3) of the Capital Gains Tax (Amendment) Act, 1978, he and the person from whom he acquired them (hereafter in this subsection referred to as ‘the previous owner') fell to be treated for the purposes of the Capital Gains Tax Act, 1975, as if his acquisition were for a consideration of such an amount as would secure that, on the disposal under which he acquired it, neither a gain nor a loss accrued to the previous owner,

then, the previous owner's acquisition of the interest shall be treated as his acquisition of it.

(b) If the previous owner acquired the units disposed of on or after the 6th day of April, 1994, and in circumstances similar to those referred to in paragraph (a), then, his predecessor's acquisition of the units shall be treated for the purposes of this section as the previous owner's acquistion, and so on back through previous acquisitions in similar circumstances until the first such acquisition before the 6th day of April, 1994, or, as the case may be, until an acquisition on a disposal on or after that date.

(4) If an undertaking for collective investment was not carrying on a collective investment business on the 25th day of May, 1993, this section shall apply as respects payments by, or disposals of units in, that undertaking as if—

(a) ‘on or after the 6th day of April, 1994' were deleted from subsections (1) and (2) (a), and

(b) paragraph (b) were deleted from subsection (2).".

Amendment agreed to.

NEW SECTION.

Mr. B. Ahern

I move amendment No. 64:

In page 50, before section 14, to insert the following new section:

16.—Section 31 of the Capital Gains Tax Act, 1975, is hereby amended in subsection (4) by the insertion after "residence" of "or by virtue of section 15 (2)* of the Finance Act, 1993.".

Amendment agreed to.

NEW SECTION.

Mr. B. Ahern

I move amendment No. 65:

In page 50, before section 14, to insert the following new section:

17.—Section 18 (as amended by the Finance Act, 1991) of the Finance Act, 1989, is hereby amended—

(a) in subsection (1) by the substitution for paragraph (b) of the definition of a "specified collective investment undertaking" of the following paragraph:

"(b) save to the extent that such units are held by the undertaking itself, the qualifying management company of the undertaking or by another specified collective investment undertaking, all the holders of units in the undertaking are persons resident outside the State;",

and

(b) by the deletion of subsection (10).

NEW SECTION.

Mr. Yates

I move amendment No. 66:

In page 50, before section 14, to insert the following new section:

14.—Section 11 of the Finance Act, 1990 (loan capital interest relief on investments in B.E.S. investment Companies) is hereby repealed.

One of the measures taken in last year's Finance Bill was to abolish the question of interest payment relief for investors who were involved with the Business Expansion Scheme whereby loan capital interest repayments could be allowable against one's tax. The Minister made great play before the publication of the Finance Bill about the seed capital scheme and how the purpose of this Bill was to try to help entrepreneurs. Entrepreneurs tell me that this measure to restore interest relief would do more than anything else to stimulate investment, to help people who have often mortgaged their own homes because of business commitments under the BES. I would ask that this amendment be accepted, and I would like to know the cost involved. It is a small measure and would help entrepreneurs who tell me that of all the measures the Minister took last year — abolition of exemptions, reliefs and shelters for the business community, all 39 of them — this has had the most telling effect in inhibiting entrepreneurs from investing in BES type companies. These ventures are high risk in their nature, they are in the 10 per cent corporation tax regime and concern either internationally traded services, tourism or the manufacturing industry.

Mr. B. Ahern

Amendment No. 33 would have already extended this relief by removing the restriction.

Mr. Yates

Made it even tighter?

Mr. B. Ahern

No, it extends it for film relief.

Mr. Yates

That was not my point.

Mr. B. Ahern

The purpose of the amendment is to revoke section 11 of the Finance Act which denies tax relief on interest paid on a loan used in acquiring shares in a company which were issued on or after 20 April 1990, if a claim is made for BES relief in respect of the amount subscribed for those shares. Amendment No. 33 in my name, which we have already discussed, will widen the scope to simlarly deny interest relief if a claim for relief is made under section 35 of the 1987 Finance Act. That is the provision which grants relief for investment in films. The 1990 measure effectively dealt with an aspect of the tax system which was open to abuse in relation to BES and which has been highlighted in the media from time to time. This abuse centred on the fact that tax relief is available to directors and employees of companies in respect of interest paid on loans taken out by them to buy shares in their employing companies. This is not BES relief but rather a general relief for such interest. Its purpose is to encourage such employees and directors to become more closely identified and concerned with the development of their employing company. However, if this interest relief was combined with the BES relief, it would make the cost to the State of risk capital investment far too high.

Prior to the Finance Bill, 1990 a BES proposal came to light where it was intended to create special directorships for the company, that is BES investors, to enable them to benefit both from the tax relief on interest paid on moneys borrowed to meet the BES investment and the tax relief on the actual capital sum invested. The House would regard the granting of what would effectively be a double relief in respect of the same investment as an excessively generous use of taxpayers' money. In the circumstances it became necessary to legislate so as to deny relief for interest paid on loans supplied in acquiring shares in a company. If a claim for relief is also made under the BES you cannot claim both in respect of the actual sum. Since the 1990 measure was enacted, it has been open to the investor to pt for one relief or the other, but not both. In the light of my amendment No. 33, which moves in the opposite direction, what is now being proposed by Deputy Yates is unacceptable, having regard to the need for the 1990 restriction which I have explained, I could not accept the amendment.

Mr. Yates

I have listened carefully to the Minister. Representations were made to me that this was of significant benefit to people. I take the Minister's point and I will withdraw the amendment. I may be able to put together a stronger case for it. Since amendment No. 33 has been agreed, I assume it will not be grouped with amendment No. 66 on Report Stage, so I may get the opportunity to discuss my amendment in isolation.

Amendment, by leave, withdrawn.

Section 14, as amended, agreed to.

Sections 15 and 16 agreed to.