If I may, I shall respond to the points so ably argued by my right hon. Friend the Member for Crosby (Sir G. Page) and also speak to Government amendments Nos. 224 and 225.

The principal point underlying amendment No. 221 was raised in Committee by my right hon. Friend and also raised at an earlier stage in correspondence by my hon. Friend the Member for Eastleigh (Sir D. Price), whom I am happy to see in the Chamber. The point is a good one, as one would expect coming from two such notable sources. It is to prevent a double charge to capital gains tax and income tax under section 478 in respect of the same payments.

We have been seized of the point, and I hope that I may say, without immodesty, that we feel that amendments Nos. 224 and 225 marginally deal with the point a little more effectively than the amendment in my right hon. Friend's name. I hope that the House will feel able to accept them in place of amendment No. 221.

In a different sense, amendment No. 220 gives added force to an old principle that income should not be subject to tax twice. In practice, it is extremely unlikely that that would arise in the circumstances likely to be affected by section 478 in other than a case of avoidance. My right hon. Friend may well cite back to me the words that I uttered in respect of the previous group of amendments, but there is a motive test in section 478(3). It will therefore always be possible for a taxpayer to establish that there is no hint of tax avoidance in the particular complex of circumstances in which the charge might be raised. Therefore, at least one set of assessments would fall by the wayside.

Just in case my right hon. Friend's fears should be justified, however, we should like to reconsider the position to see whether an amendment could possibly be introduced next year—I say "possibly" because, as my right hon. Friend will be the first to realise, it may be very difficult to link the underlying income on which one charge to tax in the United Kingdom may have been raised with the sum paid to the beneficiary or person resident in the United Kingdom. There are considerable tactical problems here, but we shall certainly address our minds to his to see whether we can introduce something taut and accurate in a later Finance Bill. I hope that with that assurance my right hon. Friend will not press amendment No. 220.

I must also tell my right hon. Friend that I think, again, that it is most unlikely that under the existing legislation a payment charged to income tax under section 478 could possibly be charged to capital transfer tax, because, as he knows, there is a specific exemption in capital transfer tax legislation in respect of sums transferred that have been subject to income tax. I hope that I can reassure my right hon. Friend on that point also.

Finally, on amendment No. 223, my right hon. Friend very persuasively argues for some kind of deduction in computing relevant income for foreign taxes, administration and other expenses. I certainly have sympathy with the reasons underlying that amendment, but it would be difficult for me to recommend its acceptance, certainly as it now stands, as it would be extremely difficult to operate and might produce rather capricious results. It is not always easy to determine what are legitimate expenses abroad; nor will it always be easy to link any foreign taxes that may be charged on the underlying income of the trust or company with the particular tranche of income or assets that may be paid to United Kingdom residents.

I think that in a sense this point was ventilated by my hon. Friend the Member for Croydon, South (Sir W. Clark) in Committee. We have applied our minds to this, but the precise correlation between the income that has borne foreign tax and the payment that might be made to United Kingdom resident beneficiaries has defeated us. I must therefore advise the House that that amendment No. 223 would not achieve the object that my right hon. Friend has in mind. Again, however, as this is clearly a real problem we should like to return to it next year, although I cannot assure the House that we shall find a perfect solution.

On that basis, I hope that the House will feel able to accept Government amendments Nos. 224 and 225 and that my right hon. Friend will feel that ample justice has been done to the important points that he has raised in his amendments.