set-off of losses against profits, or com- bining these two principles when cal- -ulating the statutory income for pur- poses of assessment, in order that the State may share as a partner would do in the net results of a business over a series of years. The Federal Govern- ment has recognized the principle of averaging for the purpose of calcula- ting the rate of tax, and the principle of allowing a set-off of losses for the purpose of calculating the amount of the assessable profit, but these prin- ciples have not been fully accepted in the legislation of the States. The in- squity of a system which does not recognize such principles is illustrated in the Report of the Queensland Land Settlement Advisory Board, 1927, para- graphs 118-126. We recommend that the principle of averaging or of allow- ing a set-off for losses should be fully recognized by the Australian Govern- ments in making assessments for in- come tax. 4. Double Taxation (Great Britain and Australia—Commonwealth and In- terstate Tax). —It is alleged, and we believe, that the arrangements to avoid double taxation of income in Australia are not yet wholly satisfactory. This matter is one of considerable impor- tance in view of the necessity for attracting capital to Australian enter- prise, because the investor is scared by the idea of double taxation. We, therefore, suggest that every effort should be made by the Governments and the taxing authorities to further any action which is being taken to remedy the anomaly of such a double imposition. We also suggest that the true basis for any final determination is to charge the taxpayer the higher of the two taxes that may be legally imposed by two taxation authorities concurrently, leaving such authorities to apportion such amount, though we think that it might be equitably apportioned by division between two authorities in the ratio of the agreed claims by each of them, and that the taxpayer should only be required to deal with one taxation authority and pay oue, the larger, imposition. 5. Taxation of Shipping.—We had placed before us an alleged grievance of the overseas shipping companies. 'n the words of the Report of the mperial Economic Committee the posi- sion is as follows:— In the case of he non-resident ship-owner, the Tederal Act assumes an Australian rofit equal to 10 per cent. of the wmount received for freight, passen- ers and mails shipped at Australian yorts for carriage overseas. The taxa- sion is applicable to both liners and ramps and is accompanied by power 0 refuse clearance of a ship until the sax is paid, or satisfactory arrange- nents made for its payment. Similar onditions apply generally as regards he State taxation, but the percentage n this case is generally 5 per cent. There is no option under the Federal \ct, or under the Acts of the separate States, of claiming an assessment om -ealised profits. In Western Austra- ia, as the law is drawn, a ship-owner s taxed on an assumed net income »f 5 per cent. of the gross proceeds of all inward and outward traffic; but it ‘s stated that in practice the assess- ment is based on the outward traffic mly.”’ It was alleged to us that the arbi- rary proportion of the freight is more han the actual profits, and that no llowance is made for losses. We sug- rest that the ship-owners should for- nulate proposals for the taxation of she profits of shipping on the same yasis as other income, and that the jovernments should be prepared to wecept such proposals if they are equit- ible and practicable. 6. Foreign Firms and Companies Yelling in Australia.—As a result of suggestions we have received, we re- ommend that any necessary amend- nents to the law should be made to srevent the avoidance of income tax hy companies and/or persons im- yorting goods into Australia through he medium of subsidiary companies wnd Jor agents; so as to secure the pay- ment of the appropriate tax on the eal profits of such companies and/or ersons. 7. Inheritance Duties.—It is sug- zested that a similar course to that suggested in paragraph 2 might be »ursued in regard to inheritance luties, i.e., that such taxes, both for tha States and for the Commonwealth.