asked the Minister for Finance if Saorstát Revenue receives from the British Treasury 2/8 in the pound income tax deducted in respect of the dividends paid by Messrs. Arthur Guinness, Son & Co., Ltd., to their shareholders who are resident in the Saorstát, and if it is the case that the Revenue Commissioners refuse to make any refund to claimants whose total income would be less than the figure at which they would be liable to pay income tax, and, if so, whether he will give directions that a refund be made to such people.
CEISTEANNA—QUESTIONS. ORAL ANSWERS. - MESSRS. ARTHUR GUINNESS, SON, & CO., LTD.: SHAREHOLDERS AND THEIR INCOME TAX.
The answer to the first part of the question is in the negative; that is to say, no income tax has been received from the British Treasury in respect of the dividends paid by Messrs. Arthur Guinness, Son & Co., Ltd., to their shareholders. The company is assessed direct to Saorstát income tax (subject to double taxation relief) in accordance with the provisions of Section 12, sub-section (4) of the Finance Act, 1923. It is registered and controlled in Great Britain, and I am advised that it is not entitled to deduct Saorstát Eireann income from its dividends. In fact, no such deduction is made by the company. In these circumstances the shareholders are not entitled to claim repayment of any portion of the Saorstát income tax paid by the company.