Clause 15. — (Extension of Double Taxation Relief in Respect of Certain Dividends.)

Part of Orders of the Day — Finance Bill – in the House of Commons at 12:00 am on 4 June 1964.

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Photo of Mr Alan Green Mr Alan Green , Preston South 12:00, 4 June 1964

I beg the hon and learned Gentleman's pardon. We do not expect any problem about that at all. I will explain why in this way. We would agree that if it were an individual shareholder owing a true minority interest—I start again with an extreme because I believe that it will be more illustrative; let us say an individual shareholder owning only 2 per cent. of the shares of the overseas company—it might well be very difficult for him to obtain the information he would need in order to get any benefit from the Clause. But if it is a company with a substantial shareholding—and 25 per cent. is substantial—or if it is, under the terms of the suggested Amendment, a company within a group of companies, we feel confident that with its own technical resources and with such a large share of the investment overseas—this would apply whether there were one or two companies concerned—it would have little difficulty in getting the information needed to substantiate a claim to relief under the Clause.

So we have looked at the situation where more than one company might be involved and have come firmly to the conclusion that because they have the resources to look after themselves—whereas an individual with a small holding might not have—we do not believe that there will be any difficulties.

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