With your permission I propose to take Nos. 27 and 28 together.
I move amendment No. 27:
In page 85, in subsection (2) line 50, to delete " applies in respect of the distribution or ".
Amendments Nos. 27 and 28 are drafting amendments. The first one is similar to the amendments which we have accepted to section 90. The second amendment is designed to ensure that an amount included in such an assessment under Case IV of Schedule D shall not be treated as income for any other purpose.
I move amendment No. 28:
In page 85, after line 58, to insert a new subsection as follows :
" (4) Any amount on which by virtue of this section income tax is charged on a company by an assessment under Case IV of Schedule D shall not be regarded as income of the company for any purpose of the Tax Acts.".
This is similar to section 90. It deals with the case where a company after becoming resident here distributes profits earned before residence here commenced and which, for that reason, did not suffer Irish tax. In such a case the company would be assessed to income tax under Case IV of Schedule D in an amount equal to the tax credit in respect of the distribution. An example was circulated.
