I move that the Bill be now read a Second Time. As Deputies are well aware this Bill is introduced because of the paramount necessity at the present time that we should do everything possible to stimulate production and exports arising out of increased production. It is part of the general scheme of measures designed towards that end which were announced by the Taoiseach on behalf of the Government on the 5th October last.
Unfortunately we are all only too well aware of the necessity to step up exports to the greatest possible degree. However, it is not always fully appreciated or understood that, in relation to our exports and imports, we have to consider not merely the problems created by the comparative volumes of the one and the other but also the problems that are created by the worsening in the terms of trade, in other words, the position in which we are in international markets forced to pay more for the things we have to import and receive less for the things we have available for export.
In the first three-quarters of this year that worsening of the terms of trade added no less than £10,000,000 to the trade deficit when compared to 1953. It is of interest to note that from 1953 down to the present time the terms of trade were worsening all the time for us whereas from 1951 to 1953 they were improving. The rise in import prices between the third quarter of 1953 and the third quarter of 1956, which are the latest available figures, amounted to 8 per cent. and the fall in export prices amounted to 3 per cent. The worsening that those figures disclosed added no less than £3,000,000 to our import bill for the third quarter of this year and resulted in the receipts from our exports being reduced by £.6 millions. The total of £3.6 millions or one-third of the trade deficit in those months was caused by the worsening in the terms of trade loan.
Those factors make it clear that efforts must be made and inducements must be given to ensure that our production can be increased and that with an increase in production it will be possible to get a greater volume of exports. If we do not get that greater volume of exports we will not be able to sustain imports, including imports of raw material for industry, at the level that all of us would wish. As I said, this Bill is one part of the proposals of the Government towards that end. It is the part that deals with the tax incentive. The main reasons for the introduction of the Bill are the provisions to stimulate coal production and to stimulate exports. In addition to those two main provisions I have also taken the opportunity of adding certain other matters to the Bill which will be of assistance in another way.
The easement of the manner in which wear and tear is given for certain machinery allied to mines will, I think, be of assistance, and in addition I have included in the Bill a provision for industrial building allowances so as to stimulate building activity. The Bill also includes the appropriate provisions to arrange the prize bond issue to which I referred recently and which, as I said then, I hope to introduce early in the new year.
So far as the actual sections and machinery of the Bill are concerned Deputies can see that it is divided into five parts. The first part, which consists of Sections 1, 2 and 3, deals with the normal construction provisions and gives the usual right of appeal from the determinations of the Revenue Commissioners which are included in Section 2 and which are normal in our income-tax code. Section 3 is the section that deals with the wear and tear deduction to which I referred. It provides a more favourable method of computing wear and tear deductions in the case of machinery used in a short life mine or in a smelter working in conjunction with it. Under the section the wear and tear deductions may at the option of the trader—and I would stress at the option of the trader—be computed by reference to the expected life of the mine and the probable scrap value of machinery when the mine ceases to be worked. It seems to me obviously fair that if you have machinery usable only—as apart from its scrap value— in connection with any particular mine, the deduction should be in relation to the length of the operations of that mine rather than the useful life of the machinery and I think it is on that basis that the deduction should be calculated. As I say the option is given in this section for the trader to choose this method if it suits him.
Part II of the Bill deals with the tax relief for profits from coal mining. In Sections 4 and 5 are what one might term the machinery sections. Section 4 deals with appropriate definitions and Section 5 provides that relief under this part of the Bill will be available only to a company which is incorporated, managed and controlled in the State. In so doing it follows the line of the Bill we dealt with here for another type of mining approximately 12 months ago. Section 6 ensures that new coal-mining operations will be regarded as a separate trade for the purpose of assessment to income-tax. It also provides that, in the assessment to income-tax of profits from new coal-mining operations, corporation profits tax will be regarded as having been paid in full notwithstanding that it may be abated under Section 7 of the Bill. The purpose of that is to ensure that the company will get the full 50 per cent. remission. If that provision were not included in paragraph (b) of Section 6, the effect would be that such company would not receive the full 50 per cent. remission but that income-tax would be charged on the part of the corporation profits tax that had been remitted. That, of course, is not our intention, the intention being that 50 per cent. of the profits calculated in this way will be relieved both from income-tax and from corporation profits tax.
Section 7 provides relief from income-tax and corporation profits tax from new coal-mining operations, that is to say, coal-mining operations which are commenced after the 30th September, 1956. The 30th September, 1956, was chosen as the appropriate date as being the last day of the month prior to the announcement by the Taoiseach on behalf of the Government that a concession such as this was about to be introduced. The section accords a 50 per cent. exemption from income-tax for the year of assessment in which the new mining operations are commenced and subsequent years up to and including the 5th April, 1967. There is also granted a 50 per cent. exemption from corporation profits tax for accounting periods and parts of accounting periods from the date of the commencement of the new mining operations up to the 30th September, 1966. The difference between the two concluding dates arises, of course, because corporation profits tax is charged on the actual period rather than the income-tax year.
Section 8 provides relief from income-tax and corporation profits tax in the case of profits from existing coal-mining operations. The section lays down that, over a period of ten years, income-tax and corporation profits tax for each year on profits referable to an excess of the volume of output of coal over the volume of output of coal in the year ended 30th December, 1956, will be relieved to the extent of 50 per cent. The ten year period as regards income-tax may begin with any one of the three income-tax years ending on the 5th April, 1960. The option to choose which year it will start, again, rests with the company concerned. As regards corporation profits tax, the ten years' period begins on the 1st October, 1956. This section also provides that, in the assessment to income-tax of profits from existing coal-mining operations, corporation profits tax will be regarded as having been paid in full notwithstanding that it may be abated under the section. That provision is, of course, for the same reason as that applying in the earlier section to which I previously referred.
Section 9 deals with the dividends paid by coal-mining companies which obtain relief under this part of the Bill. The rate of income-tax which may be deducted from any such dividend is to be reduced by reference to the relief and any repayments of income-tax are to be governed accordingly. The section also provides that no relief under this part of the Bill will be given in respect of any income which goes to pay charges, such as debenture interest, from which the coal-mining company is entitled to deduct income-tax.
It is further provided by this section that, where a reduced rate of income-tax is deductible from a dividend under this part of the Bill, the amount of the dividend will, for surtax purposes, be reduced to correspond with the reduction in the rate of income-tax deduction.
Those sections cover the provisions in relation to coal-mining. I hope and I believe that, with the introduction of this Bill, containing now those sections dealing with coal-mining, we will succeed in obtaining in relation to what coal deposits there may be in the country the same degree of interest and activity as we have already obtained in respect of what I may roughly call metallic ores by virtue of the tax incentives that were introduced last year. Nobody can deny that, following the introduction of those tax incentives last year and the arrangements that were then made, we have—we are all glad to see—far more interest in mining in Ireland than ever before in the history of the State.
Part III of the Bill deals with profits from exports. The appropriate definitions are contained in Section 10 and the standard period is defined in Section 11 as being the year to the 30th September, 1956. This period will apply even though the company which carries on the trade in the year of claim may not be the person who carried it on in the year ending on the 30th September, 1956.
Sections 12 and 13 define the scheme of relief from income-tax and corporation profits tax under this Part of the Bill, the former section dealing with income-tax and the latter with corporation profits tax. The sections provide, in effect, that, over a five-year period, tax for each year on the profit represented by an increase in the value of a company's exports of manufactured goods, that is to say, goods manufactured by the exporter, over the value of such exports, if any, in the standard period, shall, in so far as that profit is used in the development of the company's business in the State, be reduced by 50 per cent. The five-year period as regards income-tax may begin with any one of the three income-tax years ending on the 5th April, 1960. Again, it is for the company concerned to decide, at its own option, in which of these three years it wishes the relief to begin. As regards corporation profits tax, the five-year period begins on the 1st October, 1956.
Section 13 also makes provision for the necessary apportionments for purposes of corporation profits tax where relief is claimed for an accounting period of less than 12 months or where there is a transfer of a part of a trade.
The section also prescribes that, in the assessment to income-tax of propose fits from exports, corporation profits tax will be regarded as having been paid in full notwithstanding that it may be abated under this section.
The House will note that in relation to the relief on exports it has been provided in these sections that the profit must be used for ploughing back and in the development of the company's business. I think everybody will agree that that is a desirable provision. That provision is not included in relation to the coal-mining provisions because mines are a wasting asset and it would not be realistic to include the provision in relation to coal mines.
Section 14 provides for the owner obtaining the relief from tax because there is a succession in the trade or where there is a transfer of part of a trade or where permanent cessation in a trade occurs. In relation to exports, as apart from coal mining, there is not uniformity of exports; it is not possible to relate the profits to the volume in the same way as it can be related to volume of coal. Accordingly the House will note that in this part of the Bill the standard taken is of value and it is by reference to the increase in the value of exports that the concession applies.
There is the same exemption in Section 15 of this part of the Bill as there was in the former portion to which I have referred in regard to debenture interest and so forth. When a company is entitled to retain from the payee tax from his interest it would not be right that it should get relief for such tax so retained. The section accordingly deals with that.
Part IV of the Bill deals with the industrial building allowance. Section 16 provides for a deduction of 10 per cent. of the capital expenditure incurred by a trader on or after the 13th September, 1956, in the construction of any industrial building to be occupied by him.
Section 17 defines the building or structure to which the allowance applies. The buildings are those used for the pursuance of the trade such as a mill, factory or other similar premises or building for the purposes of hotel keeping. I think everybody would agree that it is desirable that industrial building should be stimulated and that everybody will also agree, having regard to the importance of the tourist trade as an invisible export, that it is desirable to include hotels in this provision. The effect, I hope, will be that hotel keepers will now realise that under this concession it would be wise, not merely for the country as a whole, but for their own sakes, to go ahead and build new hotel accommodation so as to ensure that the amount of accommodation available will be such as to meet the need which we have if we wish to increase our tourist trade.
Section 18 defines the basis period by reference to which the industrial building allowance is to be granted. Normally the basis period will be the accounting period ending in the year preceding the year of assessment.
Section 19 provides that the industrial building allowance should not be given in respect of expenditure incurred in the acquisition of a site, or for work on the site except in so far as it relates to the preparation of the ground for the purpose of receiving the foundations of the building.
Section 20 enables a company to obtain an industrial building allowance in relation to corporation profits tax where it would be eligible for such allowance in relation to computing income-tax.
I think Deputies will recollect that there has been pressure for some considerable period for an industrial allowance for buildings of the type such as I have provided for in this section of the Bill and I feel sure that its effect will be to stimulate industrial building and therefore greater industrial production in the way in which it is desired.
As I mentioned in the beginning I am also taking advantage of this opportunity to include in the Bill the appropriate reference to prize bonds and Part V of the Bill provides the legislative authority required in connection with the issue of prize bonds. Prize bonds will differ in important measures from existing State borrowing. Instead of earning interest or dividends they will participate in drawing for substantial cash prizes free of income-tax and surtax. They will not be dealt in on the stock exchange but will be repayable in full at any time. They will combine full security with the chance of a large capital money prize normally found only in a speculative venture. Prize bonds will form a useful addition to the existing measures for the encouragement of savings and should appeal to a large section of the community if not to all. There is a considerable public demand for opportunities to win large sums of money and the State should not ignore this fact in its efforts to obtain money in respect of capital development.
Prize bonds will have an outstanding advantage in that regard in that the money cannot be lost and that it may be recovered by the owners whenever they wish to do so. Because of this also it is proposed to exclude the scheme from the scope of the Gaming and Lotteries Act of 1956. In addition, the House will note that under Section 24 I have provided exemption from stamp duty in respect of certain documents which will have to be utilised in connection with prize bonds.
I recommend this Bill to the House as part of a scheme to provide, by tax incentive, additional production in coal mining and additional production for export. The success which followed the introduction of the Mineral Tax Concession Bill in the early part of this year is, I hope, a happy augury in relation to the coal-mining provisions included in this Bill. The provisions that are included here in relation to profits from exports should now enable our industrialists to go out and, with the additional facilities they will now have available to them, be able to seek foreign markets, markets outside this country which are so desperately necessary in the national interest. The industrial buildings allowances should assist in modernising factory premises and in the erection of new premises. The Prize Bonds Scheme will form a useful addition to the manner in which the State, for the purposes particularly of production and capital projects, can obtain the funds necessary for these projects. For all these reasons, I commend the Bill to the House.