This section supersedes section 364 of the Income Tax Act, 1967, which is being repealed. It provides for the estimation of the reduced Irish tax credit under section 167 where, at the time of making a distribution the full details necessary to compute the double taxation relief due to a company are not available.
SECTION 168.
Question proposed: " That section 168 stand part of the Bill."
Question put and agreed to.
NEW SECTION.
I move amendment No. 38c:
In page 150, before section 169, to insert a new section as follows:
" 169.—Where, apart from this section, a company would be entitled to deductions in respect of—
(a) interest under the provisions of paragraph 1 (2) of Part III of Schedule 6 to the Income Tax Act, 1967 (provisions for giving effect to agreements for avoidance of double taxation in the case of the United Kingdom), and
(b) charges on income which are payments of interest to which the provisions of section 10 (6) apply,
the aggregate amount of the deductions which may be made under those provisions shall not exceed the amount specified in section 10 (6).".
The purpose of the amendment is to delete the provisions in paragraph (a) of the original section. That paragraph referred to section 76 of the Income Tax Act, 1967 which provided for certain interest payable out of income from foreign securities and possessions which will be deducted in computing the amount of the income. Section 76 of the Income Tax Act, 1967, will not, however, apply for purposes of corporation tax. Instead, interest is payable out of income from foreign securities and possessions and will, where appropriate qualify for relief from corporation tax as charges on income covered by section 10 of this Bill. Paragraph (c) of the original section refers to charges on income and this reference is preserved in paragraph (b) of the new section.
Adoption of this amendment involves deletion of section 169.
Amendment agreed to.