Perhaps it would be appropriate if I asked a question at this stage. I indicated last night the problem that confronts us in dealing with section 21. You are necessarily applying provisions of the Income Tax Act where appropriate and required and you are removing the application of provisions out of the income tax code from corporation tax. We should be able to see the relevancy of this. In view of the time factor, we adopted a policy that the Minister is in a position to say that this is consolidation or necessary application of the Acts enforcing his concept of having a special corporation tax that embraces both the old CPT and the income tax. That will suffice now. If we were to do it in the way we should do it, if time permitted, we would be inquiring as to application on the one hand and exclusion on the other. Is there any area in between, of simple omission that would have an effective influence in changing the existing position machinery-wise? I am not talking of the actual incidence of tax because it is the question again of the machinery of implementing the Act. Can the Minister say if there is by omission here either that certain provisions of the Income Tax Acts which are not explicitly mentioned may apply, or are there some provisions of the Income Tax Acts that apply at the moment whether for benefit of the Revenue or the taxpayer that just automatically drop out because they are not included in the provisions of section 21? I hope I have made the point clear.
SECTION 21.
I think I understand this—if I do not, we will have further clarification. This section applies for corporation tax purposes the existing income tax system of capital allowances. For this purpose the wording of the relevant income tax sections is amended in the First Schedule. There are certain income tax provisions which are not relevant for corporation tax purposes and those are the parts which are excluded. Subsection (2) excludes various provisions which are not relevant for corporation tax purposes. They are concerned with such matters as basis periods for years of assessment and the manner of making claims for capital allowances for income tax purposes. For instance, in the corporation tax system the capital allowances will be given without claim. The right to disclaim certain of these allowances, that is the accelerated capital allowances, is given by section 14 to which we made reference this morning.
One can quite understand that the unforeseen can crop up in this but can the Minister say that the examination was exhaustive, that to the Minister's official knowledge, information and belief there is no in-between area and that there are neither omissions nor inclusions?
I am satisfied that the examination was both exhaustive and painstaking.
It was intended to be exhaustive.