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Income Tax
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No further progress was made in the matter, despite the Chairman and the General Manager attending a conference of Trustee Savings Banks initiated by the Actuary of the York County Savings Bank in 1923. However, in 1924, a letter was received from the Actuary of the Edinburgh Savings Bank with regard to the question of Income Tax on depositors' interest:

 

Edinburgh Savings Bank,

(16 North Bank Street)

 

Dear Sir,

 

You may remember us having a talk about the re-claiming of Income Tax when you and two of the representatives of the Birmingham Corporation called here about eighteen months ago, and I have been wondering if the Local Inspector of Taxes insists on your supplying him with the names and addresses of all depositors who receive interest in excess of £5, and what proportion of your total number these amount to.

 

For the last eight years we have been supplying the names of all depositors in our Special Investment Department who receive such interest, but this year the demand has been made on us to give the information for both Departments. This, we consider, is taking a most unfair advantage of the reading of the Income Tax Act of 1918 as the sole reason for our making a Claim for Return of Tax is because the interest in the Investment Department is taxed before receipt, whereas that in the Ordinary Department comes direct from the Government without deduction.

 

All the Trustee Banks in the country are up in arms against this monstrous demand, and representatives of our Banks have had interviews in London with the Treasury Officials and with the Chairman of the Board of Inland Revenue. What the results of these interviews are, we are still waiting to hear, but, meantime, the Local Inspectors of Taxes are pressing their demands for these lists, which we are, at present, holding up to see if something will not emerge from the representations made by us.

 

Not only does the supplying of these further lists impose a great deal of work on us, but the local Surveyors will find that the extra expense of administration in their offices will cost more than they will ever get out of it. I should say that fully 70% of the people getting over £5 of interest are exempt from Tax, as we can judge from the cards which are returned to us yearly. We have offered to give the Inland Revenue 30% of the tax deducted and only ask to get 70%, but they are not disposed to accept this very fair offer.

 

If you could inform me as to your present practice, I shall be much obliged.

 

Yours faithfully,

(Sgd) K Stirling,

Actuary.

 

The Manager,

Municipal Savings Bank,

Birmingham.

 

This letter appears to have stimulated the BMB into reviving the topic, and a report of the General Purposes Sub-Committee was presented to the General Committee on June 16th 1924:

 

Income Tax on Depositors' Interest.

 

Your Sub-Committee have recently given further consideration to the question of the requirements of the Inland Revenue Authorities with respect to Income Tax Liability on interest allowed to depositors whereby the bank are required to furnish particulars of depositors who have been credited with over £5 interest during the year. In this connection it will be recalled that the suggestion was some time ago advanced on behalf of the bank as to a compounded payment being made by the bank of a percentage of the standard rate of tax on interest up to and including £15.

 

Your Sub-Committee had an opportunity of discussing this question with the Right Honourable Neville Chamberlain, MP, and as a result, the Trustee Savings Banks were approached with a view to concerted action being taken to obtain the desired amendment in the requirements of the Inland Revenue Authorities. The accompanying Reports sets out the subsequent action taken and the present position of the matter.

 

Report on Conferences in respect of amendment of Income Tax Act 1918

relative to Savings Banks.

 

Conferences have recently taken place between the Trustee Savings Banks Association and the Birmingham Municipal Bank with a view to joint action in an endeavour to obtain suitable amendments to the present Finance Bill, and interviews have taken place with the Right Honourable Neville Chamberlain MP who has consented to act therein.

 

The present law requires returns to be made to the Inspector of Taxes of the names and addresses of all depositors who have been paid or credited with interest during the year in excess of £5, together with the amount of such payment or credit in the individual cases. It is this requirement which the Conference believe should be amended.

 

The Birmingham Municipal Bank endeavoured in 1920 and 1922, to obtain an amendment, and in 1918, the General Manager appeared before the Royal Commission on Income Tax with the same object. The Trustee Savings Banks were not inclined to co-operate with the Birmingham Municipal Bank in 1920 and 1922 as the requirement did not seriously affect them, but they now find that they are expected to make returns in every instance as in the case of the Municipal Bank.

 

It should be explained that Trustee Savings Banks are divided into two departments, viz: (1) An ordinary department which accepts deposits at 2½% interest to an unlimited extent, the whole of which deposits are invested with the National Debt Commissioners, who allow £2. 17. 6 per cent interest to cover working expenses of the Bank; and (2) a Special Investment Department which accepts deposits in block sums, at a slightly higher rate of interest, to a total holding of £500, which may be invested in such securities as the Trustees, with the concurrence of HM Treasury, may determine. The Municipal Bank is, so far as accepting deposits is concerned, a combination of the two departments mentioned and, so far as investment of funds is concerned, equivalent to the Special Investment Department referred to.

 

An interview with Mr Chamberlain took place in London on May 22nd 1924 at which Mr W P Cobbett, Chairman of the Manchester and Salford Savings Bank, and your General Manager were present. The result of such interview was that Mr Chamberlain promised to introduce a suitable amendment providing he was fully authorised to do so by the Trustee Savings Banks Association, and Mr Cobbett undertook to convene a meeting of the Association to give that authority. Mr Chamberlain pointed out that time was very short, having regard to the stage which the Finance Bill had then reached.

 

A Conference of the Association was held at Manchester on the 29th May at which all the larger Trustee Savings Banks were represented. The General Manager was specially invited to attend the meeting. After a lengthy discussion a resolution was passed authorising Mr Cobbett and your General Manager to take what action they considered most suitable to secure - (1) an entire exemption from making the return so far as the depositors in the ordinary department are concerned and (2) to raise the figure of £5 to £15.

 

The following day Mr Cobbett and your General Manager conferred on the steps to be taken, and decided to wire Mr Chamberlain for an appointment, and to instruct Messrs Dyson Bell & Co, parliamentary agents to Messrs Cobbett & Son, to draft a suitable clause or clauses and submit same forthwith to Mr Chamberlain. Mr Chamberlain fixed the 3rd or 4th June for the interview and the latter date was decided upon.

 

The deputation which waited upon Mr Chamberlain on the 4th June consisted of Mr Spencer, J Portal, JP (Chairman of the Trustee Savings Banks Association, and Chairman of the London Savings Bank); Mr W P Cobbett (Deputy Chairman of the Association and Chairman of the Manchester and Salford Savings Bank); Mr Henderson, Actuary of the Glasgow Savings Bank; Mr Councillor Appleby (Chairman of your Committee) and your General Manager. The following drafted amendments were considered and agreed to:

 

(1)       Paragraph (ii) of the proviso to sub-section (3) (b) of Section 39 of the Income Tax Act 1918 shall apply and have effect as if the sum of fifteen pounds had been referred to instead of the sum of five pounds.

 

(2)       The requirement contained in the said paragraph (ii) as amended by this Section as to the making of returns by a savings bank and any branch thereof as a condition of the right of such bank to exemption from tax under Schedules C & D in respect of interest paid or credited to depositors shall only apply with respect to depositors to whom interest is paid or credited in the year for which exemption is claimed by the bank out of the income of its funds other than interest and dividends arising from investments with the National Debt Commissioners and to an amount exceeding in the case of any such depositor the said sum of fifteen pounds.

 

The effect of the amendment, so far as the Municipal Bank is concerned, is to raise the limit to £15, but to the Trustee Savings Banks it means no returns being made in the case of depositors in the ordinary department and the raising of the limit in the special investment department. From the conversations it would appear that Mr Latter, KC, has given his considered opinion that the present demand on Trustee Savings Banks for returns in respect of depositors in the ordinary department is illegal, having regard to the peculiar character of the investments, and as yet no returns have been made. If the proposed amendment is secured it will make the law clear - if it is not secured the Trustee Savings Banks will be at liberty to take the case to the Courts for a decision.

 

It was decided that every Trustee Savings Bank should be circularised and urged to actively associate themselves, and their members of Parliament, in this matter, and at Mr Chamberlain's suggestion a circular is to be addressed to every Member of Parliament on the subject, asking for support to the amended clauses.

 

Mr Chamberlain will table the amendments for consideration in the Committee stage of the Bill, probably on the 16th June.

 

At its meeting on July 25th 1924, the Committee were informed that in consequence of Neville Chamberlain's action, the following clause had been agreed on the report stage for inclusion in the Finance Bill:

 

Clause introduced by the Chancellor of the Exchequer in the Finance Bill 1924,

which has now received its third reading in the House of Commons.

 

Paragraph (ii) of the proviso to paragraph (b) of sub-section (3) of section thirty-nine of The Income Tax Act, 1918 (which sub-section provides for the exemption from tax of certain income of savings banks), shall have effect as though for the words "where the interest paid or credited to any depositor in the year for which exemption is claimed by the bank exceeds the sum of five pounds", there were substituted the words "where in the year for which exemption is claimed by the bank, the interest paid or credited to any depositor out of the income of its funds, other than interest and dividends arising from investments with the National Debt Commissioners, exceeds the sum of fifteen pounds."

 

Thus, thanks to the Bank's historical and Birmingham connection with Neville Chamberlain, the objective of raising the reporting level to £15 was achieved.

 

A second outcome from the Bank's pursuit of raising the Income Tax reporting limit was the involvement of the Trustee Savings Banks Association. The Bank decided to investigate the possibility of additional involvement with the Savings Bank movement and, on July 20th 1936, the Bank Committee passed the following resolution:

 

That the proposal to constitute a joint committee of representatives of the Trustee Savings Banks Association and the Municipal Bank to consider matters of mutual interest be approved, and that the Chairman and General Manager be appointed to represent the Bank and attend meetings when convened.

 

In lieu of the round sum "Estimated Charges" for Income Tax debited to the Income and Expenditure Accounts from 1923 to 1932,  exact amounts were shown for the financial years to March 31st 1950. In the years of the Second World War, payments were also made for War Damage Contributions, as detailed below:

 

Year Ended

March 31st

Income Tax

(£)

War Damage

Contributions

(£)

Total (£)

1933

35,636

 

35,636

1934

19,680

 

19,680

1935

3,788

 

3,788

1936

11,874

 

11,874

1937

14,200

 

14,200

1938

22,012

 

22,012

1939

22,998

 

22,998

1940

57,444

 

57,444

1941

69,759

 

69,759

1942

44,693

5,386

50,079

1943

41,593

5,894

47,487

1944

48,781

3,952

52,733

1945

8,201

2,523

10,724

1946

24,822

2,267

27,089

1947

1,625

 

1,625

1948

20,647

 

20,647

1949

15,785

 

15,785

1950

19,649

 

19,649

 

In the following nine financial years, the charge in the Income and Expenditure Accounts for Income Tax included a Reserve amount in four of the years:

 

Year Ended

March 31st

Reserve

(£)

Charge for

the Year

(£)

Total (£)

1951

7,500

40,273

47,773

1952

5,000

19,775

24,775

1953

7,500

15,461

22,961

1954

 

27,179

27,179

1955

 

15,509

15,509

1956

 

40,986

40,986

1957

 

43,659

43,659

1958

 

57,283

57,283

1959

15,000

42,211

57,211

 

Following the introduction of the No 2 Department in 1957, the liability for Income Tax applied to both savings departments. However, no charge was made in the No 2 Department until 1959/60.

 

Year Ended

March 31st

Charge for

the Year

No 1 Dept.

(£)

Charge for

the Year

No 2 Dept.

(£)

Total (£)

1960

50,910

1,139

52,049

1961

71,925

459

72,384

1962

81,646

96

81,742

1963

107,837

0

107,837

1964

101,325

0

101,325

1965

127,577

216

127,793

1966

25,688

4,541

30,229

No taxation was charged in the years 1966/67 to 1975/76, the Bank benefiting from the fact that Local Authorities were exempt from taxation in this period. That exemption ceased when the Bank became a Trustee Savings Bank and profits were subject to Corporation Tax:

Year Ended

November 20th

Charge for

the Year

(£)

1976

600,000

1977

1,013,000

1978

1,080,000

1979

2,397,000

 
 
 
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