§ Mr. PowellI beg to move, in page 19, line 16, to leave out subsection (3) and insert:
(3) Where a dividend on shares in a company which is an Overseas Trade Corporation is receivable by, and constitutes trading income of, another Overseas Trade Corporation, that other Overseas Trade Corporation shall, subject to the provisions of this Part of this Act relating to double taxation relief, be entitled to repayment of income tax deducted from the dividend under the said section one hundred and eighty-four and subsections (2) to (4) of the said section one hundred and ninety shall apply for the purposes of this subsection as they apply for the purposes of that section.Clause 25 provides for what, in the jargon which we have evolved in these debates, we have come to know as the switching of exempt trading income between the subsidiaries and the principal in a group where all the companies concerned are overseas trade corporations. There is, however, one type of case in which that switching has not been made possible, and that is where one subsidiary has a holding, which will, of course, necessarily be a minority holding, in another subsidiary, on which dividends would be payable.The substitution of the new subsection (3) will cover that case, as well as all the other cases where switching might be desired which are covered by the Clause as it stands.
§ Amendment agreed to.