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Dominion laws in respect of that excess, any shareholder whose
‘appropriate rate’ exceeds the standard rate of United Kingdom
income tax may claim further relief, but on the other hand if
the shareholder’s ‘appropriate rate’ is less than the standard
rate, then he has received excessive relief and inspectors of
taxes are acting within their powers in making the necessary
adjustments in individual cases.

In order to obtain authority for the deduction of United
Kingdom income tax at a reduced rate from dividends it is
necessary, before payment, to furnish the Revenue Authorities
with full particulars regarding the Dominion income tax
paid by the company and to produce Dominion revenue
receipts as evidence of the payment of such taxes, together
with a detailed statement reconciling the amount of the
assessment with the figures in the printed accounts.

The following is suggested as a suitable form in which to
furnish the necessary particulars: —

I. Amount of profits assessed.

2. Deductions allowed therefrom.

Taxable amount actually charged.

Date of end of Dominion year for which taxes charged
Rate of Duty.

Amount of duty charged.

Details of Income exempted from Dominion taxation.
Details of Income subjected to Dominion income tax
before receipt.

Evidence of payment.

As it is often found impossible in practice for the revenue
authorities to be furnished with particulars of the Dominion
taxation in respect of the Dominion year corresponding to the
British income tax year of assessment in time to pass on the
relief to shareholders by means of a reduced deduction of
United Kingdom income tax, the Board of Inland Revenue are
usually willing to grant relief on the basis of the Dominion
income tax paid for the year preceding the British income
tax year of assessment.

In the case of Foreign and Colonial Companies United
Kingdom income tax is chargeable on the ‘gross’ amount of the
dividend, .e. the declared amount of the dividend written up
by an amount of Dominion income tax equal to the amount of
relief granted, unless the Dominion concerned grants com-
plementary relief from Dominion income tax in respect of
the payment of United Kingdom income tax when the dividend
is written up by reference to the full rate of the Dominion
income tax,

SECRETARIAL PRACTICE

A.