I beg to move, "That the Clause be read a Second time."

This matter was first raised two years ago by my hon. Friend the Member for West Nottingham (Mr. Caporn) and again last week on the Committee stage. Our Amendment on that occasion was not as well drafted as it might have been, because we overlooked certain governing words at the beginning of Section 30 of the Finance Act, 1922. When it was reached in Committee, at, I think, half-an-hour after midnight the Financial Secretary used certain words which were interpreted by the Deputy-Chairman as carrying the meaning of the Amendment to a point where it imposed a charge on the revenue. I do not think that was the intention of my hon. Friend the Financial Secretary, but the words happened to be ambiguous. However, as a result the debate came to a premature end, from my point of view, although probably the rest of the Committee were glad, in view of the late hour. I have retabled that Amendment in its present form, which will carry out the purpose I had in mind, and I am grateful to you, Mr. Deputy-Speaker, for giving me the opportunity of raising the matter again. In the Act of 1922 a provision was made that where the residue of an estate went to a charity and where the estate was not wound up for more than a year after the death of the testator, Income Tax should not be payable on any income accruing in respect of the part of the estate that was ultimately to go to the charity from one year after the death until the money was handed over. That was an advance.

I am raising this matter at the request of an accountant in my constituency who saw a charity defrauded, as he regarded it, of a substantial sum owing to the fact that for the 12 months this money, which ultimately was going to the charity, was subject to pay Income Tax on the ground that it was still lying in the estate. I think that if someone dies and leaves money to a charity—I am dealing only with cases where it is the residue that goes to the charity—the money ought to be deemed to belong to the charity from the very day on which the person dies, and the Treasury should not collect Income Tax from what is, in effect, the income of a charity. I think this new Clause would give effect to that view. I have not been able to work out an estimate of what this new Clause would cost. Obviously it would be a fluctuating amount, because in some years the sums left to charity which would come under the terms of this Clause would be larger than in other years, and I do not think there are any published statistics which would enable an outsider to formulate a precise estimate.

I shall not be very much surprised if the Financial Secretary says that he cannot accept the Clause, because on the Report stage of a Finance Bill a new Clause which would cost a substantial amount is generally resisted. But there is still sitting a Departmental Committee, I think, on the Income Tax law, and some day or another they will report. They have had seven years to consider their problems, and it is said that the first seven years are always the worst in the life of a Departmental Committee. I have no doubt they are approaching the end of their task, and when they have done so I hope that the Treasury, in formulating any legislation on their report, will give consideration to the point which I have put forward. It may be that when the time for consideration comes things will be more prosperous, and it may then be easier for the Treasury to make this concession, but on broad general grounds I see no reason why a charity should pay Income Tax on any part of what is, in fact, its income.