Dáil Éireann díospóireacht -
Tuesday, 23 Apr 1963

Vol. 202 No. 1

Financial Resolutions. - Resolution No. 9—Income Tax.

Dr. Ryan

I move:—

THAT where the whole or any part of any annual payment is payable out of a dividend from which by virtue of Section 7 of the Finance (Profits of Certain Mines) (Temporary Relief from Taxation) Act, 1956 (No. 8 of 1956), or Section 9 or Section 15 of the Finance (Miscellaneous Provisions) Act, 1956 (No. 47 of 1956), income tax either is not deductible or is deductible at a reduced rate, the annual payment, or that part thereof, as the case may be, shall be treated as not having been paid out of profits or gains brought into charge to tax and, subject to the provisions of the Act giving effect to this Resolution, Rule 21 of the General Rules applicable to Schedules A, B, C, D and E of the Income Tax Act, 1918, shall apply accordingly.

Mr. Sweetman

What is this all about?

Dr. Ryan

Where a company has got relief of income tax on exports and, let us say, it is paying debenture interest, it would look as if it could deduct the income tax on that interest but it appears there was some defect in the law where the subsidiary company could claim the full income tax back again. This is to provide that where the company is making payment of that kind the amount which could be got back is the average income tax paid by the exporter, not the full income tax.

Mr. Sweetman

Is this something the same as the British income tax, where you pay net tax?

Dr. Ryan

I do not think that Britain has this difficulty. It is an export tax business.

Mr. Sweetman

I think it has.

Dr. Ryan

The same principle, I am told.

Mr. Sweetman

That is what I thought.

Resolution put and agreed to.