I move:
(1) That corporation profits tax chargeable on profits of a foreign company arising in an accounting period ending after the 31st day of December, 1928, shall, subject to the provisions of this section, be charged, levied and paid at the rate of seven and one-half per cent. in lieu of the rate of five per cent.
(2) That this resolution shall not apply to corporation profits tax chargeable on profits of a foreign company arising in an accounting period in respect of which such foreign company satisfies the Revenue Commissioners either
(a) that during the whole of such accounting period all the members of such foreign company were resident outside Saorstát Eireann, or
(b) that
(i) in the case of the accounting period current on the 1st day of January 1929, during the whole of the time from the 31st day of December 1928 to the end of such accounting period, or (ii) in the case of the accounting period current at the expiration of six months from the day on which such foreign company commenced to carry on business in Saorstát Eireann during the whole of the time from the expiration of such six months to the end of such accounting period, or
(iii) in the case of any other accounting period, during the whole of such accounting period such foreign company maintained in Saorstát Eireann a branch register of its members resident in Saorstát Eireann and that according to the law of the country in which such foreign company is incorporated and the law of Saorstát Eireann all stock and shares registered in such branch register and held by persons domiciled in Saorstát Eireann are or are deemed to be property situate in Saorstát Eireann for the purposes of assessment to death duties in such country and in Saorstát Eireann, or
(c) that such foreign company commenced to carry on trade or business in Saorstát Eireann within six months before the end of such accounting period.
(3) That this resolution shall be read with Part V. of the Finance Act, 1920.
It is not expected to produce any additional corporation profits tax. The ordinary corporation profits tax is at the rate of 5/-. This applies to foreign companies and is at the rate of 7/6, but it will not be levied where the foreign company sets up what is called a Colonial Register here. The setting up of a Colonial Register means that the shares of the company belong to Irish shareholders registered or situated here, and in that case we will get the whole of the death duties. For example, if Messrs. Guinness set up a Colonial Register here the result will be that Irish shareholders whose shares are registered in the Colonial Register will have estates on which, when they die, we will get the death duties. At present a considerable proportion of death duties goes to the British Exchequer.
