I have received representations but I do not have them to hand. I dealt with this on the Second Stage when I said that Deputies may be aware that it was not feasible in the past to frame legislation to give group relief because of different bases of assessment for income tax and corporation profits tax. Likewise, it would be even less feasible to frame legislative provisions to provide group relief for accounting periods or parts of accounting periods falling before 6th April, 1976, since income tax and corporation profits tax as well as corporation tax would have to be comprehended.
The Revenue Commissioners have assured me that they will consider sympathetically any particular cases which might be put to them for the grant of group relief in respect of accounting periods or parts of accounting periods falling before 6th April, 1976. Such an administrative solution would not, of course, mean a departure from what is set out in Part XI of the Bill with regard to either qualification for group relief or the nature of the relief allowed. Obviously, it would be necessary to have any such claims supported by all the relevant facts in relation to the companies concerned. I received representations about a group situation which has enjoyed such relief and who have written expressing their appreciation of relief granted in that form. Statutorily we would be creating a great deal of verbiage if we tried to handle the three different taxes as existing before, or deeming them to exist before, the 6th April, 1976.