§ Mr. MacDermot
I beg to move Amendment No. 239, in page 32, line 31, after "order" to insert:contained in a statutory instrument".The Amendment remedies a fault in a technical definition. The Clause restricts United Kingdom tax on dividends paid by United Kingdom companies to residents of certain countries specified in Schedule 8. The provisions apply only for the years 1966–67 and 1967–68, and the Treasury may extend that period by order. We failed to provide in the Bill that the order should be published as a Statutory Instrument, which will ensure that all interested parties may find out where they stand.
§ Amendment agreed to.
§ Question proposed, That the Clause, as amended, stand part of the Bill.
§ Mrs. Thatcher
A matter has been raised with me by one of my constituents and it was the subject of Amendment No. 99. It refers to subsection (1), which begins:This section applies to dividends paid in the period comprising the years 1966–67 and 1967–68 …The question is whether the word "paid" should be read to include "deemed to be paid". I doubt whether that interpretation would be correct.
Some serious consequences would follow if it does not include "deemed to be paid," because the United Kingdom subsidiary of a non-resident parent company which had paid dividends in 1965–66 in excess of its standard amount would apparently be required to account for Income Tax at 8s. 3d. on the excess deemed to have been paid at April, 1966. If, however, the dividend had been paid at that date, the tax under Schedule F would have been at a considerably reduced rate.
523 If the words "deemed to be paid" need to be inserted, I have no doubt that the hon. and learned Gentleman will do so on Report. I should be grateful for some clarification. If the hon. and learned Gentleman is not in a position to give clarification now, perhaps he could give me the information by letter.
§ Mr. MacDermot
I will gladly take advantage of that final suggestion. We were a little mystified as to exactly what the Amendment in question was aimed at. The hon. Lady has explained it very clearly. May I consider the point and let her know?
§ Question put and agreed to.
§ Clause, as amended, ordered to stand part of the Bill.
§ Schedule 8 agreed to.