Second Reading Speech
The primary purpose of this Bill is to delete from the Income Tax and Social Services Contribution Assessment Act the provisions relating to agreements for the relief of international double taxation of incomes so that those agreements may be implemented in separate legislation. As I have already indicated in the speech just recently delivered, corresponding provisions are proposed in an Income Tax (International Agreements) Bill.
Effect is at present given to the double taxation agreement made in 1946 by the Commonwealth and the United Kingdom by the provisions of Part IIIB of the Income Tax and Social Services Contribution Assessment Act and the inclusion of a copy of the agreement as the Third Schedule to that Act. It is now proposed to omit both Part IIIB and the Third Schedule from that Act.
Continuity in the application of the agreement is provided for in the Income Tax (International Agreements) Bill.
Prior to the 1946 agreement with the United Kingdom coming into force, partial relief from double taxation was provided for by the allowance of rebates under section 159 of the Assessment Act. That section has, however, been superseded by the provisions of the agreement and the section is now redundant. It is accordingly to be repealed as from the commencement of the income year which commenced on 1st July last. The repeal will not, however, affect the rights of taxpayers to be allowed rebates under the section in respect of income derived before the agreement became effective.
The Bill also contains proposals of a drafting nature made necessary by the renumbering last year of certain provisions of the Assessment Act.
The Bill leaves open the way for the Income Tax (International Agreements) Bill under which all provisions relating to international income tax agreements will be brought together in one Act.
The explanatory memorandum to which I referred in the course of my speech on the Income Tax (International Agreements) Bill covers the clauses of this amending Assessment Bill also.
19th November 1953.