May I just remind the hon. Gentleman of an Amendment which stands in my name further down on the Paper to the effect that
The amount of income of any company which under Section 21 of the Finance Act, 1922, the Special Commissioners may direct shall for the purpose of assessment to Super-tax in any year or other period, be deemed to be the income of the Members, shall notwithstanding anything in that Section contained not exceed such part of the income of the company as for the purpose of that Section shall be a reasonable part thereof for the company to distribute.
This Amendment is intended to meet the case quoted by my hon. Friend, and it does so in somewhat different words. I suggest there should be no difficulty in the Government accepting my Amendment. I would remind the Financial Secretary that I sent him a draft of that Amendment two or three weeks ago when the question had been raised in the City of London, and it had been assumed by some financial papers and authorities that there was an error in the drafting of the Finance Bill. For my part I have not the slightest doubt whatever that that is so. The hon. Member for Farnham (Mr. Samuel) will remember that it was due to an Amendment moved by me that the first draft of the Clause was withdrawn altogether, and the right hon. Member for Hillhead (Sir R. Horne) subsequently put in the present Clause. Never for one moment was it suggested that the person who honestly made a mistake or had a difference of opinion with the Income Tax
Commissioners as to what was a reasonable amount to be distributed should be penalised simply because of an error of judgment. That seems to me to be grossly unfair. In view of the fact that the Government, until this afternoon, have given us no hope whatever of what they intend to do—on the contrary, the Financial Secretary wrote definitely to me that he feared there was no chance of the Government accepting my Amendment—and after what has passed now, I ask to have something a little more definite than the statement of the Financial Secretary, before this Amendment is withdrawn. I hope my hon. Friends will press with me for an assurance that, in any case, we shall receive the support of the Government in some Amendment which shall rectify the particular unfair penalty in the Clause as it now stands.