§ 24. Mr. McEnteeasked the Chancellor of the Exchequer how much money Great Britain has received from the U.S.A. since 1939 in respect of the exhibition of British films in that country; and are such sums of money subject to taxation in the U.S.A.
§ The Chancellor of the Exchequer (Sir John Anderson)I regret that the information asked for in the first part of the Question is not available. As regards the second part of the Question, any income from the exhibition in the United States of America of British films would, I understand, be subject to United States taxation.
§ 25. Mr. McEnteeasked the Chancellor of the Exchequer if he is aware that American film-producing interests are estimated in resposible quarters to have received in 1943 some £20,000,000 and since 1939 close on £80,000,000 sterling from Great Britain in respect of the hire of their films; and if such sums are sub- 2159 ject to deduction for income tax and excess profits tax.
§ Sir J. AndersonI am aware that very considerable sums are payable to American film-producing interests for American films exhibited in this country. Such sums are not income for they have to cover production expenses and they are accordingly not subject to income tax by way of deduction, but income tax is charged in this country on such amounts as represent profits attributable to the distribution and exhibition of the films as distinct from profits attributable to their manufacture in America. Liability to Excess Profits Tax extends to the profits of any trade or business carried on in this country, but again would not extend to the manufacturing profits of a nonresident concern manufacturing abroad.
§ Mr. McEnteeWhile it is difficult to understand the complicated answer, is there not quite a difference between the treatment of money in America and the treatment of money for similar purposes in this country; in other words, do not the Americans have all the advantages and we have none.
§ Sir J. AndersonIt may be that there is a difference, as my hon. Friend suggests, but, as the matter is both complicated and to some degree delicate, I would prefer to see Questions on that subject on the Paper.
§ Sir Herbert WilliamsIs it not the case that Americans easily evade all Income Tax merely by charging their agents and distributors in this country, known as renters, high prices, so that no profit appears to arise in this country.
§ Sir J. AndersonI would rather see that Question on the Paper.