I should like to preface my remarks by saying that we have received some recent representations on this particular section and the following section which are being considered in the Department of Finance and the Office of the Revenue Commissioners. I am not in a position to say what the impact of the representations may be, but if the need arises I will, of course, bring it to the attention of the House on Report Stage.
The section as drafted brings into charge to corporation tax, foreign interest and dividends arising to a nonresident bank, insurance company or other person carrying on a business of dealing in stocks, shares or securities in the State through a branch or agency where the foreign securities are attributable to the branch or agency. In the absence of such a provision, income exempt from income tax in the hands of non-residents under section 50 or section 462 of the Income Tax Act, 1967, would be exempt from corporation tax because section 11 exempts from corporation tax any income which is exempt from income tax.
The section also provides for a restriction of expenses in computing profits or losses or management expenses where interest on certain Government securities is excluded in computing income or profits for corporation tax purposes and the expenses are attributable to those securities.
