I move:—
That in the case of property passing on the death of a person who dies on or after the 1st day of April, 1924,
(a) Section 47 of the Finance (No. 2) Act, 1915, shall not operate to exempt from any taxation to which but for that section as adapted it would be liable, the capital or interest of any of the securities therein referred to so long as they are in the beneficial ownership of persons who are either domiciled or ordinarily resident in Great Britain or Northern Ireland, and
(b) Section 63 of the Finance Act, 1916, shall not operate to exempt from any taxation to which but for that section as adapted it would be liable, the capital or interest of any of the securities therein referred to so long as they are in the beneficial ownership of persons who are either domiciled or, being British subjects, are ordinarily resident in Great Britain or Northern Ireland.
In this case if a person holds certain British securities registered, say, in the Bank of Ireland, and he is domiciled in Ireland, those securities are not exempt for the purpose of death duties. If, however, he holds those same securities registered in the Bank of Ireland, and he is domiciled, say, in the Six Counties or Great Britain, he is exempt from Saorstát tax, although he is liable to British tax. Now, the change we propose here is to make him liable to Saorstát tax. Then, the Double Taxation Relief Act would come into operation, only one duty would be charged, but we would get our share of it, which we do not get at the present time.