§ The Solicitor-GeneralI beg to move Amendment No. 150, in page 41, line 30, after "representatives"), to insert:
as if it were an amount of chargeable gains accruing".This also, I think, is an entirely uncontroversial Amendment. The Committee will have observed the purpose of the Clause. It not infrequently happens nowadays, when there are so many exchange controls and other restrictions on the movement of funds and currency, that someone earns a sum of money, whether by way of income or by way of 1343 capital gains, in a foreign country, and is unable, maybe for a long period, to bring the proceeds to this country.The purpose of the Clause, which it is now sought to amend, is to ensure that he shall not be chargeable for tax before the money is available to him here. It may happen that someone earns the money in, say, year 1 in the country of origin, but is unable to bring the proceeds here until year 10. As the Clause now stands, it might happen that, although he would be taxed in the year in which the money was available in this country, he might still be taxed in respect of the first year.
It is to avoid that possible ambiguity that the Amendment is tabled. There is a distinction between taxing "in" the year and taxing "for" the year. It is to meet that point that I move the Amendment.
§ Amendment agreed to.
§ Clause, as amended, ordered to stand part of the Bill.