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Special Committee Corporation Tax Bill, 1975 debate -
Wednesday, 18 Feb 1976

SECTION 15.

I move amendment No. 4b:

In page 21, subsection (5), line 9, to delete " one year" and to substitute " two years".

Amendment agreed to.
Question proposed: " That section 15, as amended, stand part of the Bill."

By way of explanation, the section provides for the deduction in computing profits for corporation tax purposes of management expenses of resident investment companies, including savings banks, disbursed on or after 6th April, 1976. Expenses incurred before that date will be relieved from income tax under section 214 of the Income Tax Act, 1967 which is being repealed by the Third Schedule of this Bill with effect from 1976-77. Transitional relief is provided by section 186 and the Fifth Schedule. The section contains a provision which has no counterpart in existing legislation under which unabsorbed management expenses and charges on income may be carried forward for set off against income of a subsequent period. Alternatively, unabsorbed management expenses and charges on income may be set off against franked investment income. Franked investment income is defined in section 24 as the sum of a dividend or other distributions and the tax credit in respect of it.

The Minister is apparently satisfied the interests directly concerned here are agreeable?

I am sorry to say that nobody has written to say " thank you ".

This is purely consolidation. We can look at it if we are told in each section that you have received or will receive something against the section.

I would agree to that. Take the last case now. If the Minister were simply to mention that this was consolidation in regard to the point involved, it would save the Minister's breath.

Question put and agreed to.
SECTION 16.

I move amendment No. 5:

In page 21, subsection (3), line 45, after " is a time" to insert the following:

" immedietely preceding the accounting period first mentioned in subsection (2) ".

This is another drafting amendment being moved for the same reasons as amendment No. 4.

Amendment agreed to.
Question proposed: " That section 16, as amended, stand part of the Bill."

Broadly speaking this section incorporates the loss reliefs which are already available under sections 307 to 309 of the Income Tax Act, 1967, and as respects corporation profits tax under section 25 of the Finance Act, 1964. It provides broadly that a trading loss may be carried forward from an accounting period and set off against income of the same trade for a later accounting period.

Question put and agreed to.
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