330 
SECRETARIAL PRACTICE 
United King- Under agreement made between the British Government and 
dom Income the Government of the Irish Free State in respect of double 
pox and Jrish income tax (see s. 23 of Finance Act, 1926 and s. 21 of Finance 
Income Taz. Act, 1928), a person resident in the Irish Free State and not 
resident in Great Gritain or Northern Ireland is entitled to 
exemption from United Kingdom income tax in respect of 
income arising in Great Britain or Northern Ireland and a 
person resident in Great Britain or Northern Ireland, and not 
resident in the Irish Free State is entitled to exemption from 
Irish Free State income tax in respect of income arising in the 
Irish Free State. 
Special provision is made in the agreement for relief in cases 
of persons resident both in Great Britain or Northern Ireland 
and in the Irish Free State. 
Appeals. 
Reliefs. 
Salaries. 
Under Clause 4 of the agreement a company is deemed to be 
resident in the country in which its business is managed and 
controlled. 
If a liability has not been agreed with the inspector and 
a return has been made in accordance with the company’s 
views, it will generally be found that an assessment will be 
made on the larger figure in accordance with the inspector’s 
contention. Upon receipt of the Notice of Charge or notice of 
assessment the secretary should give in writing the necessary 
notice of appeal, stating the grounds of appeal quite generally, 
and whether the appeal is to the General or Special Commis- 
sioners. It is desirable to register this communication, which 
should be made within 21 days. As it has been assumed that 
all necessary documents are already before the Revenue nothing 
further remains to be done until the case is brought before 
the Commissioners. 
Where a business ceases, the liability for the broken period 
at the end is reduced to the actual profits for that period, less 
any debts [s. 31 of Finance Act, 1926], and provision is also 
made for repayment of any tax overpaid or the raising of an 
additional assessment as the case may require. 
Under Schedule E, the secretary has an important function 
to discharge—making a statutory return of salaries on the 
prescribed form [No. 46 or 46 (a)]. It should be noted that 
this Return should include the directors, all the staff whose 
whole-time remuneration brings them over the limit of 
liability, and also pensioners and any who receive fees of 
any kind, whatever the amount, for part-time work; as 
distinct from payment for specific tasks, e.g. solicitors’ and 
architects’ fees. Round sums paid annually for expenses, 
bonuses. etc.. should be specified.