§ Mr. Templeasked the Chancellor of the Exchequer in what circumstances where a charitable deed of covenant, executed by a close company, is allowable under Section 52 of the Finance Act, 1965, against profits for Corporation, Tax purposes and against profits under Section 77 of the same Act for apportionment as to Income Tax, it is the practice of the 367W Inland Revenue to make an apportionment of the money paid under the deed of covenant according to Section 78 of the Act as to Surtax.
§ Mr. Harold LeverIn all circumstances, unless the effect of the apportionment would be trivial.