HC Deb 06 February 1945 vol 407 cc1893-4
63. Sir H. Williams

asked the Chancellor of the Exchequer whether he will look into the circumstances of those employees of B.O.A.C., who are engaged in flying between the United Kingdom and Canada and who, when based on Montreal, are subject to Canadian Income Tax and also have United Kingdom Income Tax deducted as well; and will he take steps to remedy this grievance.

Sir J. Anderson

I would remind my hon. Friend that provision is made, in Section 27 of the Finance Act, 1920, for granting relief in respect of the payment of Dominion Income Tax in cases where a person has paid Dominion Income Tax in respect of a part of his income and is also liable for United Kingdom Income Tax thereon.

Sir H. Williams

Is my right hon. Friend aware that his answer does not deal with the point at issue, which is that these people live part of the week in Scotland and part of the week in Montreal, and that they are presumed to be living simultaneously in both countries, when in fact they are constantly travelling to and fro? Ought they not to be treated as being domiciled in one country only?

Sir J. Anderson

That is a very wide question. I understood the Question to be concerned with relief from the burden of double taxation.

Mr. Silverman

Would the Chancellor say why he thinks this is a very wide question? Surely, the number of persons concerned is very few, and the point which the hon. Member makes is an obvious one.

Sir J. Anderson

I said I thought it was a wide question because questions of law under which domicile or residence is determined go beyond the point in my hon. Friend's Question.

Sir H. Williams

Does not the right hon. Gentleman agree that there are only a small number of people whose residence has to be determined in one country or the other, although they, perhaps, sleep two nights in Canada and two in the United Kingdom?

Sir J. Anderson

My hon. Friend has over-simplified the matter.

Mr. Silverman

Does not the right hon. Gentleman agree that it is manifestly unfair to a small number of people who are doing a very valuable service to charge them double Income Tax, one lot in the Dominion and another in this country, for circumstances which they cannot control themselves?

Sir J. Anderson

The point of my answer shows that they are not charged double tax.

Mr. Silverman

Oh, yes, they are.

Sir H. Williams

Does the same standard apply to the Prime Minister when spending a lot of his time in other countries?