I desire to move the following:—
That the Agreement made the 25th day of April, 1928, between the Government of Saorstát Eireann and the Government of Great Britain amending the Agreement made on the 14th day of April, 1926, between the said Governments in respect of double income tax shall be confirmed.
This new agreement, as I explained already in the Dáil, is necessary because of the substitution of sur-tax for super-tax. It does not in any way alter the principles or the procedure on which relief from double taxation was given. The agreement of 1926 fixed the principle of relief from double taxation so far as income tax is concerned on the basis that had been recommended by the Financial Committee of the League of Nations. Briefly, the principle on which relief is and has been given since 1926 is that residents in Saorstát Éireann are exempt from British tax, that residents in Great Britain are exempt from Saorstátax, and that people who are doubly resident are relieved to the extent of the lower of the two taxes. Before 1926 relief from double taxation was given on another basis. A person resident in Saorstát Eireann, part of whose income arose in Great Britain, was subject to Saorstát income tax on all his income, and was subject to Saorstát tax and to British tax on the part of his income which arose in Great Britain. On that part of the income which was doubly taxed he was entitled to relief from the two Governments—relief from the Saorstát to the extent of half of the lower of the two taxes, and relief from the British Government to the same extent. That meant that the claiming of repayment and the securing of relief was a very complicated and difficult business, and led to a great deal of annoyance and delay.
The new arrangement is very much simpler. As I have said, it is not quite simple in the case of people doubly resident, but there is no way of making things entirely simple for them. So far as the ordinary resident here is concerned, if he has been charged British tax he can reclaim payment on the whole on satisfying the British authorities that he is resident here. From the Exchequer point of view, the arrangement entered into in 1926 proved to be a good arrangement and gave us additional income-tax. It would be very difficult to fix a figure on it, but actually it was more beneficial to the Exchequer than the old system. So long as we continue the principle of giving relief from double taxation, I think the present arrangement is as good as can possibly be devised. I see no way in our circumstances of avoiding the giving of relief because the number of people, many of them in fairly modest circumstances, who have incomes that would be doubly taxed is very great. If there was no system of relief from double taxation many of the people from whom we get very large sums of income-tax would entirely keep out of this country and great sums would be lost. There are many people who have residences in the two countries, people with very large incomes. At present we get half the income-tax they pay. If there was no system of relief and they had to pay a double tax they would take steps to see that they were not liable to our tax at all.
Then there is the question of charities. There are great numbers of charities that are now, because they are resident here, exempt from British tax under the existing arrangement and because they are charities in the Saorstát, are exempt from our taxation. If there were no system of relief from double taxation they would be liable to British tax and they would find it impossible in any reasonable time to change their investments and escape the double taxation. There are not many countries which have the same need for a scheme of relief from double taxation as this country has.
The history of the country is the cause of that, and the very close interlocking that exists. As I have already said, the League of Nations in 1923 appointed a committee of economists who prepared a scheme of relief from double income tax and from other forms of direct taxation. We, with Great Britain, then adopted so far as income tax is concerned the scheme that is there recommended. As I have said, it is the most workable scheme that could be got. It is the simplest and most convenient scheme that there could be for taxpayers, and one which, so far as our Exchequer is concerned, is more satisfactory than the scheme which was in existence before.