This section replaces section 363 and subsections (2), (3) and (5) of section 364 of the Income Tax Act, 1967. Both of these sections are being repealed by Part II of the Fourth Schedule. The section in general provides that payment of a tax credit is to be restricted where the distribution is made out of income which, because of the allowance of double taxation relief, has borne Irish tax at a rate less than the rate of imputation. The object of this is to ensure that the Irish Revenue will not be obliged to pay to, say, an exempt shareholder more tax than the company paid on the profits out of which the distribution is made.
SECTION 167.
Question proposed: " That section 167 stand part of the Bill."
Question put and agreed to.