§ Mr. STEWARTasked the Secretary to the Treasury whether Income Tax upon dividends received abroad and brought Home is chargeable at the rate of the day upon which the taxpayer received the money abroad or at the rate of the day upon which the money was received at I Home; whether taxpayers can pay their Income Tax upon each remittance as and when received; and, in the event of dividends being reinvested abroad, is the 380W Income Tax payable at the rate of the day upon which the taxpayer received the money abroad?
§ Mr. MONTAGUDividends of foreign or colonial companies payable through an agent in this country are subject to taxation by deduction at the rate in force at the time when the paying agent is entrusted with funds for their payment, and the like dividends not entrusted to an agent in this country for payment, but realised in the United Kingdom through bankers, coupon dealers, or other persons, are subject to taxation by deduction at the rate in force at the time of realisation. Where foreign or colonial dividends are not received in such manner as to be subject to taxation by deduction, the recipient is liable to direct assessment whether the dividends are brought to this country or are spent, retained or reinvested abroad, and the basis of assessment on dividends arising from stocks or shares in any place out of the United Kingdom is the average of the income arising in the three preceding years. The rate is, of course, that imposed for the year of assessment, but as the amount on which the tax is charged does not necessarily correspond with that arising in the year of assessment, it would be misleading to say that the rate is that in force when the taxpayer received the money abroad, and for the same reason, apart from administrative difficulties, the tax cannot be paid upon each remittance as and when received.