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

Orders of the Day — Finance Bill – in the House of Commons at 12:00 am on 30 June 1964.

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Photo of Major Sir Henry D'Avigdor-Goldsmid Major Sir Henry D'Avigdor-Goldsmid , Walsall South 12:00, 30 June 1964

I beg to move Amendment No. 16, in page 13, line 45, at the end to insert: (3) For the purposes of the provisions of the Income Tax Acts mentioned in subsection (1) of this section a company shall be deemed to control, directly or indirectly, not less than one-quarter of the voting power in another company if a third company having such control also controls, directly or indirectly, not less than one-half of the voting power in the first-mentioned company. I moved a similar Amendment in Committee and withdrew it at the request of my hon. Friend the Financial Secretary, who said that he would consider the wording. Now, to my infinite surprise, he has indicated that he will accept the wording.

Photo of Mr Alan Green Mr Alan Green , Preston South

My hon. Friend is right. In Committee, I accepted the spirit and intention of the Amendment, but I asked that we should be given a chance to check the wording, as this is a technical matter. This has been done and it has been found that the wording is as unexceptionable as the spirit and the intention. I urge the acceptance of the Amendment.

Photo of Mr James Callaghan Mr James Callaghan Shadow Chancellor of the Exchequer, Member, Labour Party National Executive Committee

I am sure this is an excellent compact between the front bench and a back bench opposite, but some of us would like to know what it is all about.

Photo of Major Sir Henry D'Avigdor-Goldsmid Major Sir Henry D'Avigdor-Goldsmid , Walsall South

I was under the impression that the hon. Member for Cardiff, South-East (Mr. Callaghan) was present when we discussed this in Committee. I did not wish to take time by going over the matter again.

All that the Amendment seeks to do is to clear up the position in regard to an overseas company which may be controlled by a company operating here. The overseas company may be in a country where, for local reasons, it is not possible to admit of outside control and resort has been made to an intermediary holding company to produce the same result in such a way to conform with the prescribed conditions of the company overseas.

I am sorry that I did not explain this when I moved the Amendment tonight, but it is on the record in Committe. I hope that with that explanation the hon. Member for Cardiff, South-East will be satisfied.

Photo of Mr James Callaghan Mr James Callaghan Shadow Chancellor of the Exchequer, Member, Labour Party National Executive Committee

I speak again by leave of the House. I wondered how Rootes and Chrysler could, in certain circumstances, be included in this.

Amendment agreed to.

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