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Chamber and committees

Justice 2 Committee, 14 Mar 2001

Meeting date: Wednesday, March 14, 2001


Contents


Subordinate Legislation

The Convener:

Iain Gray is with us. I apologise for keeping you waiting, minister. We were not quorate at 9.15, but you can rest assured that I shall deal with that when the rest of the committee appears.

I invite you to speak to and move motion S1M-1701, on the approval of the draft Limited Liability Partnerships (Scotland) Regulations 2001.

The Deputy Minister for Justice (Iain Gray):

I am happy to say a few words about the Limited Liability Partnerships Act 2000 and the new form of business association that it will bring about: the limited liability partnership. Such a partnership will combine the organisational flexibility and tax status of a partnership with limited liability for its members. That limited liability is possible because the partnership is a legal person separate from its members. That means that a partnership will be able to enter into contracts and hold property and will be able to continue in existence even when there are changes in its membership. A limited liability partnership is therefore rather closer to a company than to a partnership; that has been the guide to framing the regulations.

The creation of types of business associations is a matter reserved to the UK Government, and the department with responsibility for that is the Department of Trade and Industry. Accordingly, the UK Government introduced the Limited Liability Partnerships Bill in 1999. Although the creation of those partnerships is reserved, the legislation impacts on a number of devolved areas of Scots law. On 24 June 1999, the Scottish Parliament considered and approved a Sewel motion that enabled the Limited Liability Partnerships Bill to progress in the UK Parliament.

Scottish ministers have powers within devolved competence to make regulations under the Limited Liability Partnerships Act 2000 in relation to LLPs. That is what the committee is considering today. Because the powers in the act allow ministers to amend primary legislation by statutory instrument, section 17(6) provides for that to be done by the affirmative procedure. The UK Government has laid before the UK Parliament separate regulations that provide for England and Wales in all areas and for Scotland within the reserved areas. Those regulations were considered and approved by the House of Commons yesterday and the House of Lords is expected to consider them next week.

The Scottish regulations are necessary to apply Scots law in relation to the winding up and insolvency of LLPs, to ensure that LLPs registered in Scotland can create floating charges over their assets, to apply the Criminal Procedure (Scotland) Act 1995 to the members of LLPs, and to provide for the execution of documents by LLPs in accordance with Scots law.

In essence, the regulations will give LLPs parity of treatment with companies. The policy is to make LLPs available throughout Great Britain, so both sets of regulations have been designed to be as consistent as possible, with the result that the regulations may look extremely bulky. However, the approach of making them apply other statutes by reference has been taken to highlight where the changes in company and insolvency law have been made. We hope that that will make it easier for users to identify the changes.

The intention is that both the UK regulations and the Scottish regulations will come into force on 6 April 2001, which will allow those who wish to take up LLP status to do so at the start of a new tax year. Taken as a whole package, the Scottish regulations, the DTI regulations and the Limited Liability Partnerships Act 2000 provide a flexible and useful mechanism for the creation of a new business form that will keep Great Britain at the forefront of international practice. I commend the regulations to the committee.

I move,

That the Justice 2 Committee recommends that the draft Limited Liability Partnerships (Scotland) Regulations 2001 be approved.

Members will note that the Subordinate Legislation Committee considered the instrument on 27 February and had no comment to make.

To what extent are the regulations welcomed by businesses and partnerships?

Iain Gray:

As you would expect, the most significant consultation on the new form of partnership took place before the initial legislation was introduced. The DTI distributed a pre-legislative consultation paper to about 2,000 organisations and individuals, but the department reckons that 5,000 received it. The bulk of the 5,000 were businesses and professional associations that represented or had an interest in the professions that might take up this new kind of business association. Their response was very largely positive, because they felt that such an association would give some protection to professionals who were members of partnerships.

Okay. We have up to 90 minutes for discussion, if we need it.

We could read through the regulations slowly.

Scott Barrie (Dunfermline West) (Lab):

I do not intend to take up 90 minutes. The explanatory note to the regulations makes it clear why we are taking this route and highlights some of the pitfalls if we did not, such as the possibility that businesses would leave the UK for more advantageous regimes elsewhere. Although I understand the positive aspects of the proposal for companies, does it have any down sides?

Iain Gray:

It is difficult to see any. Although the change will certainly give significant protection to members of partnerships, the key point is that the existing forms of partnership for some of the professions now seem very outdated. They date back to a time when professional partnerships were small and local, whereas such partnerships are now increasingly UK-wide and international. As a result, the liability that falls on a member of a partnership can be terrifying. The legislation modernises a kind of association that is past its time.

The question is the impact on the clients of partnerships, and the protections that they would have would be very similar to the protections that they have when they deal with a company. Any weaknesses in that respect would therefore reflect general weaknesses in consumer law's provisions for consumer protection vis-à-vis companies. This legislation would not be the place to deal with that issue.

I apologise for briefly detaining the minister outside the committee room.

Were chambers of commerce included in the consultation on the DTI document?

Very much so.

What was their reaction?

Iain Gray:

The response has been almost entirely positive, for the reasons that I outlined in my response to Mr Barrie. The consultees certainly believed that the proposal would give appropriate and additional protection to professionals in partnerships, which would obviously include the members of chambers of commerce.

I have no further questions, and I certainly do not want to hold up the legislation.

Minister, I heard your comments about the DTI consultation. However, why were consumer groups not included in that process?

Iain Gray:

They were to some extent. The Consumer Association and the National Council for Voluntary Organisations were both consulted, on the assumption that they would both further consult their membership. It would be only honest to point out that, compared with the much larger number of businesses and professional organisations that were consulted, those organisations formed a relatively small part of the process. However, they were not excluded.

Did the consumer organisations flag up any issues in the consultation?

No. They felt that the change was both appropriate and overdue.

The Convener:

On balance, professionals and businesses have chosen to form partnerships instead of companies. Will the regulations overall mean that the benefits of the partnership structure will remain, but that the members of partnerships will be protected because they will no longer be jointly or severally liable?

That is correct.

What are the benefits of the legislation?

As you have pointed out, there are benefits as far as the liability of members of the partnership is concerned. Furthermore, the legislation will give partnerships access to some elements of the tax regime that they do not yet have.

Do the new regulations mean that there will be other burdens for a new partnership under the Companies Act 1985?

Iain Gray:

Yes. The new limited liability partnership carries some burdens that are very similar to current burdens on companies such as the requirement to produce an annual report and accounts. If we were asked about the difference between a very large partnership under the LLP regulations and a small company, the answer would be not a great deal.

So the net effect of winding up a partnership under these regulations would be almost similar to winding up a company under the Companies Act 1985.

Absolutely. Indeed, some of the regulations that are before the committee today will ensure that the Scots law that applies to such circumstances will include LLPs and companies.

If there are no further questions, I will put the question on the motion. The question is, that motion S1M-1701, in the name of Iain Gray, be agreed to. Are we agreed?

Motion agreed to.

That the Justice 2 Committee recommends that the draft Limited Liability Partnerships (Scotland) Regulations 2001 be approved.

We agreed under item 1 that the committee would go into private session for items 3, 4 and 5.

Meeting continued in private.

Meeting continued public.

The Convener:

At this point, I want to put on record the apologies that I should have read out under item 1. We have apologies from Christine Grahame, who is unwell today, and Euan Robson, who, as members may know, has been promoted and will no longer serve on the Justice 2 Committee. We will find out in due course who Euan Robson's replacement will be.

We will now take evidence from Peter Beaton and Kirsty Finlay from the civil justice and international division of the Scottish Executive justice department.

I hope that members have had an opportunity to read the background paper on the European Communities (Matrimonial Jurisdiction and Judgements) (Scotland) Regulations 2001 (SSI 2001/36). Before we hear evidence from Peter Beaton and Kirsty Finlay, I should say that the note does not give us much information on the regulations. We should place that comment on the record and have further discussion about the matter later. Perhaps we will be clearer about the practical effect of the regulations when we have heard the evidence.

I ask our witnesses to make an opening statement.

Kirsty Finlay (Scottish Executive Justice Department):

It is important to realise that the regulations that are being discussed today serve only to implement the European Council regulation on jurisdiction and the recognition and enforcement of judgments in matrimonial matters and in matters of parental responsibility for children of both spouses, which for reasons that I imagine are fairly obvious is colloquially known as Brussels II.

This instrument, which came into effect on 1 March, changes the law in Scotland and is directly applicable to all European Union member states with the exception of Denmark. All that the Scottish statutory instrument can do is make space in our domestic legislation for the provisions of the Council regulation. The amendments in the statutory instrument simply ensure that our domestic law does not conflict with the Council regulation. I repeat that the regulation is directly applicable and remind the committee that we are not in a position to do anything about that.

The Convener:

That said, it is the role of this committee to examine what the practical effect of regulations might be. The difficulty that we have found with this regulation is in determining its practical effect. Can you give us an indication of what it might mean?

Kirsty Finlay:

I appreciate that the statutory instrument presents that difficulty. It has to be read in conjunction with the Council regulation because that regulation determines the changes in the law. Essentially, the regulation makes changes to the jurisdiction in matters of divorce, separation, annulment of marriage and parental responsibility orders that relate to children of both parties of the marriage, providing those parental responsibility orders are dealt with at the same time as the divorce proceedings.

Are there any contradictions between Scots law and European Community law under the regulations?

Peter Beaton (Scottish Executive Justice Department):

The legal order for external jurisdiction arrangements, which is governed by the Domicile and Matrimonial Proceedings Act 1973, has been changed because there are fundamentally different rules of jurisdiction in Brussels II. The pre-existing regime was founded on domicile and habitual residence for one year in Scotland. The new regime is founded primarily on habitual residence, although there is a residual domicile order, provided there has been habitual residence for six months. In a sense, that inverts the jurisdictional arrangements.

The key practical effect of the abolition of the domicile rule is that someone who is domiciled in Scotland but has been living outside Scotland and who, after separation, comes back to Scotland will no longer be able to raise an action of divorce immediately on their return: they will have to wait for six months. I will not attempt to explain how or why that is the position, but it is the policy.

The previous arrangement in relation to domicile was dependent on an idea of domicile that is found, within the EC, only in the UK and Ireland. Domicile is not known as a general connecting factor elsewhere, although it was used in the European Council Convention on Jurisdiction and the Enforcement of Judgments in Civil and Commercial Matters 1968, which is known as Brussels I. The meaning of domicile in Brussels I was subject to definition in the contracting states. We have an autonomous definition of domicile in the Civil Jurisdiction and Judgements Act 1982, but that applies only to matters covered by the Brussels I convention and the parallel convention that deals with the European economic area.

In general, the concept of domicile is known only in the legal orders in the UK and Ireland. The important part about that is that domicile arrives as a sort of gift at birth. A person is domiciled where they are born or where their parents are domiciled. That domicile of origin remains throughout their life, potentially. For example, I was born in Edinburgh. If I go to the Sierra Nevada for 20 years, my domicile of origin will revive when I come back to Edinburgh.

The Domicile and Matrimonial Proceedings Act 1973 enabled someone who was returning to their original place of domicile to reassume that domicile even if they had been domiciled elsewhere. The difference between domicile and habitual residence is that, at any given time, it is possible to have only one domicile, but it is theoretically possible to have more than one habitual residence. The other difference is that domicile is an autonomous concept, whereas habitual residence is a question of fact and is determined by the facts of every situation.

The regulation applies to the children of both spouses. What is the position for the children of further relationships?

Kirsty Finlay:

Those children are not within the scope of the Brussels II regulation. Let us look at the example of a couple who are getting divorced. One of the party has been married before, has children from a previous marriage and they live together in one family unit. At the same time as the divorce action is taking place, an action for a parental responsibility order is being undertaken as part of that divorce action. If the Brussels II regulation is being followed, the action for parental responsibility can apply only to the children of the parties that are getting divorced or separated; it does not cover children of a previous marriage.

That distinction is made?

Kirsty Finlay:

Yes, because of the narrow scope of the Brussels II regulation. As we were making space in our domestic legislation for the provisions in the regulation, we were unable to amend domestic legislation to take account of that situation.

Would that situation apply even if those stepchildren had been adopted by the step-parent?

Peter Beaton:

No, they would then be considered to be children of both parents.

As the regulation is now law, I assume that we have to work out how to apply the law correctly in our legal system.

Kirsty Finlay:

Yes.

Are you saying that because only a narrow field of the law has been affected by this new European law, there is scope to amend the regulation, having seen how the legislation is working in practice?

Peter Beaton:

We have no scope to amend the regulation by domestic legislation—

Not this one.

Peter Beaton:

What development there may be in the Community legal order is a separate question. We are addressing the regulation as it stands. With respect, I have to say that anything else is irrelevant for our present purposes.

Ms MacDonald:

Is a differentiation made between children who consider themselves part of one family when that family legally breaks up? We have introduced a law that determines how some children are to be treated as opposed to others. Surely the decision taken as regards custody and access should reflect what the children think?

Kirsty Finlay:

Yes, but if an action for access and parental responsibility is taken completely separately from the divorce action, the provisions of Brussels II and the subsequent amendments to the domestic law do not apply.

I understand that, but wonder why we went to the bother of introducing this legislation.

Kirsty Finlay:

We were obliged to make provision in our domestic law for it, as European regulations are directly applicable.

Scott Barrie:

The regulation amends four pieces of domestic legislation. The Subordinate Legislation Committee was concerned that insufficient detail was given in the background notes to explain how the regulation affects Scots law. That concern has affected some of our lines of questioning today.

I want to look at the issue from a different angle. How much consultation was undertaken with organisations in Scotland about the provisions in this regulation? I am thinking particularly of consultation with legal bodies or children's organisations?

Kirsty Finlay:

Mr Beaton's experience of the negotiations that led to the Brussels II convention make him better placed to answer that question, as the regulation is subsequent to the convention.

Peter Beaton:

The Brussels II regulation was introduced under title 4 of the treaty that established the European Community and followed the Treaty of Amsterdam coming into force. The United Kingdom Government took a political decision to opt in to the negotiations that led to the adoption of this instrument. The United Kingdom and Ireland have a protocol to the Treaty of Amsterdam that disapplies title 4 in relation to any proposals that are made unless the United Kingdom and/or Ireland indicate within three months of any proposal being made that they wish to opt in to the negotiations.

In the case of the Brussels II regulation, there was consultation with legal interests before ministers decided to opt in to the negotiations. However, there had been consultation on the substance during the negotiations leading up to the adoption of the text of the convention. As the substance of the text of the convention was taken straight through to the text of the regulation, to all intents and purposes the regulation is the same in substance as the convention. No further consultation was undertaken on the substance of the regulation, but there was consultation on whether there should be an opt-in. The consultation was not wide, but there was consultation.

Did people raise anxieties during the limited consultation that took place, or were they happy with what they saw?

Peter Beaton:

I cannot say that there was very much response on the substance but, during the consultation on the Brussels II convention, a number of people expressed concerns. There was also parliamentary scrutiny at Westminster, where certain points were made. However, the political decision that was agreed to by the Council of Ministers took into account certain of those concerns, but not all of them.

The United Kingdom was successful in achieving certain amendments that consultees recommended. The retention of a domicile ground of jurisdiction was a direct result of the consultation, as it was the singular issue that was raised by consultees. Certain issues were not taken on board, and I would not like to mention those by name.

There was general dismay about the limited scope of the regulation. That was one of the issues that produced strong arguments during the convention negotiations, but it was withdrawn from the negotiations on the regulation as the Council of Ministers decided to adopt the text of the convention that was submitted in a proposal from the Commission. At that time, therefore, there was no room for argument on the scope. Progress is being made on another initiative that affords room for argument on the scope. However, returning to Margo MacDonald's earlier point, that is irrelevant to the statutory instrument that is before the committee.

Mr Beaton said that one of the practical effects of the regulation is that a person who had been living outwith Scotland could not raise an action in the first six months of their return to Scotland. Is that seen as a disadvantage?

Peter Beaton:

It is difficult to evaluate. One of the purposes of this instrument is to try to stop parallel actions. For the record, the origin of Brussels II was a concern about cross-border divorces involving certain member states of the European Community, notably France and Germany, where there was thought to be a problem of parallel actions. There was no international legal order to deal with that. The intention was to ensure that where spouses split up and departed to their states of origin, or to two separate states within the Community, there would not be two actions leading perhaps to inconsistent results.

There is a difference in approach between the United Kingdom jurisdictions and many of the continental jurisdictions as to how to handle parallel actions. In the United Kingdom, there is a doctrine known in Latin as forum non conveniens. It was invented in Scotland, but has largely been adopted in what one might call the legal systems that derive from the Anglo-American influence. Under this doctrine, where there are two competing courts, each of them with jurisdictional competence, the court that is seised first of a process can decline to accept jurisdiction if it seems that in all the circumstances it is better for the other court to take the case, for example if there are connections with the other court or if witnesses are there.

The continental systems have a system of first come first served which, in the Brussels II regulation, is covered by article 11, which says that if two courts are seised with an action, the court that is first seised should take it and the second court should decline jurisdiction. There are those who argue that that system leads to a race to the courts and that that is undesirable in family actions, but that is the regime that we have in Brussels II. No domestic legislation has been amended to deal with that because although there are provisions in domestic legislation to deal with the declining of jurisdiction, they apply only to intra-UK cases.

The Convener:

One of the advantages of being part of the European Community is that a citizen can go to their local court and enforce European Community law; that is what is supposed to happen. I see a disadvantage for someone who is Scottish and has been away and come back; they have to wait six months. I hear what you are saying about how issues of jurisdiction and conflicting legal decisions across two countries can be tidied up, but do you agree that it is a disadvantage to the ordinary person if they have to wait six months to raise an action? That is a long time to wait.

Peter Beaton:

Anyone could take a qualitative view on that, but I would not like to comment directly on whether it is a disadvantage or an advantage. It funnels back into policy on divorce and family law generally. It has been argued by commentators that there is a disadvantage, particularly in the United Kingdom, where the revival of the domicile of origin allows an action to be raised on the connecting factor of domicile. It should be remembered that the habitual residence ground that was available under the Domicile and Matrimonial Proceedings Act 1973 required habitual residence for a year. That is retained in article 2 of the regulation as one of the connecting factors:

"the applicant is habitually resident"

in a state provided

"he or she resided there for at least a year".

Where a person who was not previously domiciled in Scotland comes to Scotland, they will have to wait a year. Where a person was previously domiciled in Scotland and that domicile revives, they have to wait only six months. Clearly there is a risk that an action can be raised if the other spouse remains in the place where the couple were living together. Under another provision of article 2, an action can be raised directly by that spouse straight away and of course it works the other way, so in the case of somebody who has been living in Scotland and goes away, the spouse who remains in Scotland is able to raise an action straight away. To some extent it cuts both ways.

Are there any other questions?

I wish to unpick that a wee bit. You said that you do not want to comment on some of the objections. Why? Is it because of the source of the comments?

Peter Beaton:

They are not necessarily directly relevant to the business that we are dealing with, it would take us quite a long time to get into them and it would probably be material for a tutorial on family law. I am not the best qualified person to do that.

Ms MacDonald:

No, my head is nipping already, but we will have to revisit this area, so we should bear in mind that objections were raised to this particular part of the regulation. When we come to consider this again, it may be interesting to hear then what the objections were.

The Convener:

I do not think that there is an answer to that. We will close the questioning. I thank Peter Beaton and Kirsty Finlay for the time that they have spent at the committee this morning. It has been useful.

The committee now has to prepare a report for Parliament on our scrutiny of these regulations. Two issues have to be included in the report. One concerns timing. Members will see from the note that the 21-day rule has been breached, which the Subordinate Legislation Committee has already drawn to our attention, so that has to go in the report. The second issue is the quality of the information available to us. We have heard in evidence this morning some of the practical effects of the regulations which, although non-controversial, it is important to draw out. It is important that people understand the practical effects of these regulations. If members agree, the report should say that in future we cannot have a note on regulations that does not contain guidance on what the regulations mean.

In both the public and the private part of this morning's meeting, the committee has had to take in a lot of detailed information on how the European Community deals with these matters. Our job is to try to make the issue real for people, so what we put in our report is important. Are there any additional factors that members feel should be included in our report to Parliament? There are none. We will circulate the text of those two key issues for approval, so members should check their e-mail for it and we will get the report signed off.