§ 62 Lieut.-Commander BURNEYasked the Chancellor of the Exchequer (1) if he will institute negotiations with the United States Treasury for the purpose of insuring that in cases where British subjects are married to United States citizens and wish to become ordinarily resident in both countries that only that portion of their income actually derived in the United States or in Great Britain shall be subject to the Income Tax and Super-tax of the country in which the money is derived, provided that an equitable scheme of taxation can be arranged between the two countries that will ensure that the subject or citizen, as the case may be, shall not have to pay in taxation an amount greater than would be the case if his or her whole income was derived from that country having the highest taxation;
(2) if he is aware that, if a British subject marries an American citizen, in many cases, owing to the double incidence of Income Tax and Super-tax, it is not possible for them after marriage to become ordinarily resident in both England and America; and will he initiate negotiations with the United States Treasury for the purpose of devising an equitable scheme of taxation in cases of British subjects married to United States citizens which will enable them to become ordinarily resident in Great Britain and the United States and ensure that the subject or citizen will not have to pay in taxation an amount greater than would be the case if his or her whole income was derived from that country having the highest taxation;
(3) if he is aware that in many cases where English subjects have married American citizens such married persons would establish residence in this country, thereby benefiting trade by their expenditure, if it were not for the fact that if they established residence in this country their gross income derived from property, trades, professions, employments, securities, stocks, shares and rents in the United States of America is subject to British Income Tax, and consequently British Super-tax; and will he consider amending the Income Tax law to enable this trade benefit to be obtained?
§ Mr. CHURCHILLI am aware of the position to which my hon. and gallant Friend refers, which illustrates a particular aspect of the problem of double taxation. The general question of double taxation is being considered by a Committee of the League of Nations, on which this country is represented. If, however, favourable indications reach me from any individual foreign country that some fair and reciprocal arrangement can be entered into, I should not feel bound to await the achievement of a general solution at Geneva.
§ Lieut-Commander BURNEYAs the United States is not a member of the League of Nations, will the right hon. Gentleman consider opening negotiations directly with that country, without waiting for the negotiations which are proceeding at Geneva?
§ Mr. CHURCHILLI have said that I should not be deterred from opening negotiations with any country by the fact that the discussions at Geneva had not yet reached a conclusion.
§ Colonel WEDGWOODHow much would it cost the Treasury if this alteration were made?
§ Mr. CHURCHILLI could not possibly say without making careful calculations, but I see no reason why advantage should not be gained by a fair and satisfactory arrangement.
§ Mr. MACQUISTENIs not the United States the only country that matters, because it is only from the United States that ladies with large fortunes come?
§ Mr. RHYSWhat guarantee has the Chancellor of the Exchequer that the United States would accept any decision reached at Geneva?
§ Mr. CHURCHILLI have never suggested that any arrangement with the United States would be dependent on any decision reached by Geneva.