I move:—
That in the case of persons carrying on the business of granting annuities—
(a) where provision is made by the Act giving effect to this Resolution for relieving from income tax in whole or in part the income of part of any such person's annuity fund (being a provision having reference to annuity contracts designed to secure superannuation benefits or other provision for a person's old age or retirement), there shall be authorised such charges to income tax as may result in particular cases from treating that part of the fund and the remainder thereof, and the annuity contracts and annuity business to which each is referable, separately for tax purposes, including, in particular, the purpose of determining how far any annuities are to be treated as paid out of profits or gains brought into charge to tax, and
(b) where any such person is not charged to tax under Case I of Schedule D of the Income Tax Act, 1918, in respect of the annuity business carried on by him, provision shall be made for charging to income tax the profits arising to him from that business or from any part of that business treated separately as aforesaid.
This is a matter with which, I am sure, my predecessor is quite familiar, as it has been before the Minister for Finance a long time. A self-employed person has not the same facilities to provide himself with a pension in his old age as an employed person has. As Deputies know, big employers usually have a superannuation scheme whereby employee and employer both make contributions not subject to income-tax. The employers' and the employees' money goes into that fund and the employees eventually get a pension from the fund. As the law stands, a self-employed person has not that facility, because if he goes to an insurance company and makes an arrangement with them to get an annuity at the age of 60 or 70, he gets only a partial remission of income-tax on the amount paid in.
The provision to be made here will enable a self-employed person to get tax terms as good as if he were in a scheme where he was working for an employer. In other words, if the scheme is approved—there will be certain safeguards; for instance, he will be allowed to go only to a certain proportion of his salary—the amount that is paid for this purpose will be exempt from income-tax and the fund that will be created by the insurance company for this purpose will be to a great extent free. Of course they will have to pay on profits—that is what this Resolution deals with—but the yield from the fund will be exempt from income-tax.
