Tax Briefing Issue 21 - March 1996

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Tax Briefing Issue 21 - March 1996 Powered By Docstoc
					                                                                                       ISSUE 21 - March 1996

Office of the Chief Inspector of Taxes

Internal Review Procedure
for Revenue Audits
Background                                    Nevertheless, it is recognised that             International News
                                              perceptions are important. To meet the
The right to have an internal review of       situation and to make taxpayers and             Double Taxation Treaties
any decision made by a Revenue                practitioners more comfortable with
official is provided under the “Charter       looking for a second opinion, the
of Rights”. The existing review               Revenue Commissioners have
procedure is initiated by a taxpayer or       nominated the Director of Customer              Capital Taxes
his/her adviser requesting that a review      Services as the person who will take
be undertaken by a superior officer. In       responsibility for the arbitration role in      New Capital Acquistions Tax Form
relation to decisions taken in Tax            relation to decisions taken in Tax              & Guide
Districts, this review is normally            Districts. The Director of Customer
undertaken by a Regional Director.            Services has no connection with the
                                              Audit Programme and has no                      Relief for Service Charges
Some practitioner and business                responsibility for its management. He
representative groups have suggested          has a direct role in promoting and
that there is a reluctance, particularly in   implementing the Charter of Rights              Urban Renewal Relief
relation to Revenue Audit, to ask for a       and in ensuring taxpayer confidence in
review by a Regional Director                 tax administration.
                                                                                              Multi-storey Car Parks
                                              The aim of this review process is to
      this officer may be perceived as        provide an objective second opinion
      being too closely involved with         within Revenue when taxpayers or tax            Revenue Audit Review
      the Tax District and the official       advisers feel :
      who carried out the audit,                                                              New Internal Review Procedure
or                                                  their viewpoint on a particular           (This Page)
      it might be thought that the                  issue has not been given due
      review would give offence to the              consideration at District level,
      official involved and have an           or                                              Direct Debit
      adverse affect on their future                that their rights under the Charter
      relations with Revenue.                       of Rights have not been fully             Payment of Preliminary Tax
There is no need for such reluctance.         or
Revenue officials fully accept that their           that the District has adopted an
decisions, including decisions relating             unreasonable approach, or an
to audits, can be reviewed either by a              approach that is
colleague or by an appeal tribunal.                 technically/legally incorrect.

                                              (Continued on page 2)

Alternative Review Process                    In this Issue

Guidelines                                                should previouslyhave been
                                                          presented to the District.                      Requests for reviews should outline the
The following points may be helpful to                                                                    specific reason why the request is being
practitioners in considering whether an                   From audit cases reviewed to date,              made and should be addressed to:
internal review of an audit is appropriate:               it is evident that some practitioners
                                                          may be looking for a review                     Mr. Joe Lynch,
      In reviewing audit cases, the                       simply because they do not like                 Director of Customer Services,
      Director of Customer Services will                  the findings arising from the audit             Office of the Chief Inspector of Taxes,
      look at all relevant aspects of the                 and, perhaps, feel that they may                Setanta Centre,
           case. He will be concerned                     get a better deal elsewhere. The                Nassau Street,
      with ensuring that the Charter of                   review process is not, of course, to            Dublin 2.
      Rights is implemented and that                      be used for such a purpose. Where
      Revenue‟s objectives, as set out in                 a review is requested, practitioners            Existing Rights and Practice
      the Charter, are furthered.                         should be able to rely on evidence,
                                                          already put forward during the                  Where they prefer, practitioners and
      Obviously, the adequacy of                          audit, to support an alternative                taxpayers can, of course, continue to
      records, explanations and co-                       result or to cast substantial doubt             contact the District‟s Regional Director,
      operation given are matters to be                   on the District findings.                       if dissatisfied with the local handling of a
      taken into account in the review                                                                    client‟s tax affairs.
      process.                                            Where the item requiring review is
      A review should not be requested                    a legal/technical issue, agents                 The review procedure outlined does
      until the District Inspector‟s                      should give their view of what                  not affect a person‟s right of appeal to
      attention has been drawn to all                     they consider the position to be. It            the Appeal Commissioners under tax
      evidence on which the taxpayer                      should be supported, as                         legislation.
      and practitioner are relying in                     appropriate, by reference to the
      support of their contention. In                     law, case law, etc.
      other words, any information in
      support of the case for a review

    TAX                                                                       Internal Review of Revenue Audit                     Page 1
    BRIEFING                                                                  International Issues                                       3
                                                                              Relief for Service Charges                                 4
                                                                              Completion of Form CT1                                     5
    Customer Service Unit,                                                    Residential Property Tax                                   5
    Office of the Chief Inspector of Taxes,                                   Stamp Duty                                                 5
    4th Floor,                                                                Capital Acquisitions Tax                                   6
                                                                                New Forms & Guide
    Setanta Centre,
    Nassau Street,                                                            Payment of Preliminary Tax by Direct Debit                   7
    Dublin 2.                                                                 Issue of Third Party Returns                                 8
                                                                              PAYE                                                         8
                                                                                 Benefit-in-kind & PAYE Allowance
                                                                              Urban Renewal Relief                                         9
    Editor:                            John Leamy                                Multi-storey Car Parks
    Telephone No.                      (01) 671 6777, Extn. 4325.             Credit Unions & D.I.R.T.                                     10
                                                                              Conacre Lettings & Farm Retirement Scheme stock values       10
    Assistant Editor:                  Rosemary O‟Rahilly                     Stock Relief for Young Farmers in Partnerships               11
    Telephone No.                      (01) 6716777, Extn. 4310.              Losses on Disposal of BES Shares                             12
    Fax No.                            (01) 6710960                           Disposal of Assets for                                       12
                                                                              consideration in excess of £100,000
                                                                              Administration of Capital Gains Tax                          13
    __________________________________________________                        Completion of Form P35                                       13
    While every effort is made to ensure that the information given           Revenue News                                                 14
    in this publication is accurate, it is not a legal document.
    Responsibility cannot be accepted for any liability incurred or
    loss suffered as a consequence of relying on any matter published


    Current Position on Ireland‟s Double Taxation Agreements
    Ireland currently has Double Taxation
    Agreements, in force, with twenty                  It is hoped that two new Double             International matters are dealt with in
    seven countries. Three of these                    Taxation Treaties, Ireland/Greece and       the following areas:
    agreements, with Russia, Israel and                Ireland/Mexico, will be finalised during
    Poland, were ratified, by both parties,            1996.                                       International Section,
    during 1995 and therefore take effect in                                                       Revenue Commissioners,
    1996. It is expected that two further              Ireland is currently in the process of      Dublin Castle,
    agreements, with Hungary and the                   renegotiating a number of its older         Dublin 2
    Czech Republic, which were ratified by             Double Taxation Agreements. These           Telephone          (01) 679 2777
    Ireland in 1995 will be ratified by our            include our treaties with: the United       Fax                (01) 679 3314
    partners in 1996 thus enabling the                 States, Belgium, Italy, France, Canada,
    treaties to take effect in 1997.                   Austria and Norway.                         International Claims, Residence and
                                                                                                   Charities Unit,
    Additionally, a Protocol to the                                                                Revenue Commissioners,
    Ireland/UK Double Taxation                         Copies of Double Taxation                   Government Offices,
    Agreement dealing with foreign                     Agreements may be purchased from            Nenagh,
    pension schemes was ratified on 21                 the                                         Co. Tipperary.
    September 1995. This applies with
    retroactive effect from 1994. Broadly it           Government Publications Sales               Callers in (01) area
    provides that an employee transferred              Office,                                     Telephone:      677 4211
    by his employer, from one State to the             Sun Alliance House,
    other for a temporary period, may                  Molesworth Street, Dublin 2.                Callers outside the (01) area:
    remain a member of an approved                                                                 Telephone        (067) 335 33
    pension scheme in the former State                                                             Fax             (067) 323 73
    while getting tax relief in the latter             Telephone           (01) 661 3111
    State.                                             Fax                 (01) 475 2760

                                               Double Taxation Treaties entered into by Ireland.
                                                        (For Tabulation see Page 16)


    Relief for Service Charges
Introduction                                                payment of a specified annual charge to
Section 7 Finance Act 1995 introduced income                independent contractors for domestic            “Tag” system
tax relief for service charges paid by individuals.         refuse collection and
The relief will be available for 1996/97 and                purchase of “tags” for domestic refuse          A variety of domestic refuse collection “tag”
subsequent years for service charges paid in full           collection by local authorities or              systems are operated throughout the country by
and on time in the preceding calendar year. The             independent contractors.                        both local authorities and independent
maximum relief in any tax year is £150 at the                                                               contractors. The “tags” can be purchased from
standard rate (27% for 1996/97).                      How tax relief is granted                             normal retail outlets as well as directly from the
                                                      Local Authority Service Charges                       service provider. claims for relief for the cost of
Service Charges Qualifying                                                                                  “tags” can be made directly to the Tax Office.
for Relief                                            The legislation requires each local authority to      Receipts will not normally be required.
                                                      submit computerised returns for each calendar
All service charges paid to:-                         year to the Revenue Commissioners detailing all       Non PAYE Taxpayers
      local authorities for the provision of          cases who have met the necessary conditions
      domestic water supply, domestic refuse          (set out below). Returns must be submitted by         Non PAYE taxpayers must claim the relief at
      collection and domestic sewage disposal,        31 January (i.e. within one month of the year         year end in their tax return.
      independent contractors for domestic            end). Where the first return is incomplete a
      refuse collection,                              supplementary return must be made within a            Holiday Homes
      group water schemes for domestic water          further month.
      supply.                                         To be included in the computerised return an          Relief is not limited to a principal private
                                                      individual must have fulfilled all of the following   residence. Accordingly, it may be claimed in
Qualifying Individuals                                conditions:                                           respect of more than one domestic residence
                                                                                                            subject to the overall limit of £150.
An individual (or his/her spouse) who is liable             all service charges must be paid in full and
for and pays the service charge will qualify for            on time (i.e. the 1995 services charges must    Business expense
the relief.                                                 be paid in full and on time to qualify for
Alternatively, an individual who pays the service           relief in 1996/97)                              Relief is not available on any amount claimed as
charge (although not liable for it) and lives, on a         arrears from earlier years           must be    a business expense. For example, where one
full-time basis, in the house which is the subject          cleared over 5 years. Accordingly, at least     supply is used for both domestic and business
of the charge can also qualify for the relief.              20% of any arrears, in addition to the 1995     purposes, relief is not available on the portion
This latter category is intended to cover                   service charge, must be paid before an          claimed as a business expense.
situations such as a son or daughter paying a               individual can qualify for relief in 1996/97
service charge on behalf of an elderly parent.              the local authority must be advised of the      General
Any claim to relief by the son/daughter must be             RSI number of the individual liable for the
accompanied by a disclaimer (Form SC1)                      service charge.                                 A percentage of all claims will be checked with
completed by the liable individual.                                                                         the Local Authority to confirm their validity.
                                                      Where a PAYE taxpayer has supplied his or
Local Authority Service                               her RSI number in sufficient time to be
Charges Arrears                                       included in the local authority return the
                                                      relief, where due, has been automatically
An individual with arrears can only qualify for       incorporated into his or her 1996/97 TFA
relief for service charges in 1996/97 if at least     certificate.
20% of the arrears are paid in addition to the
1995 service charges. The arrears do not              Claims for Relief directly to
qualify for relief.                                   Tax Offices
                                                      Taxpayers who have not advised the local
Amount of Relief                                      authority of their RSI number (or who have not
                                                      done so in sufficient time to be included in a
The amount which qualifies for relief under all       local authority return) will not be granted relief
headings is the lower of £150 or the amount paid      automatically.
(net of any discount and arrears).                    In such cases relief will be granted on due claim
The relief is calculated by reference to the          from the taxpayer.
                                                      Independent Contractors and Group Water
Actual amount paid to:-                               Schemes
     local authorities for the domestic services
     described above                                  Independent contractors and Group Water
     group schemes for domestic water supply.         Schemes are not obliged to submit computerised
                                                      returns. Relief will be granted on due claim by
Flat rate of £50 for:-                                the taxpayer. It will not normally be necessary to
                                                      provide a receipt.


    Completion of Form CT1
    Introduction                                    Losses                                                 should be entered at Panel 11
    The standard of completion of forms                                                                    Code H1.
    CT1 has generally been high. However,           Section 16(1) C.T.A. 1976
    as part of our ongoing review of the            Where relief is being claimed in respect         Income Tax
    completion of forms we wish to draw             of a trading loss incurred in a preceding
    practitioners‟ attention to the following       accounting period under Section 16(1)            Section 151 C.T.A. 1976
    matters.                                        C.T.A. 1976                                            Payments in respect of which the
                                                                                                           company is liable to account for income tax sho
    Manufacturing Relief                                  The amount of the loss being
    Where manufacturing relief is being                   claimed should be entered at               Surcharges
    claimed, the amount claimed should be                 Panel 4 Code S6.
    entered at Panel 12, Code R3.                                                                    Section 101 and 162
                                                    Section 16(2) C.T.A. 1976                        C.T.A. 1976.
    It is not sufficient to charge the profits      Where a trading loss has been incurred           Surcharges under Sections 101 and 162
    to corporation tax at the reduced rate in       in an accounting period                          in respect of accounting periods ended
    Panel 11 while omitting to input an                                                              in the 12 months preceding the
    entry in respect of the manufacturing                 Nil should be entered at Panel 1           accounting period (for which the CT1
    relief being claimed at Panel 12, Code                Code D1.                                   is being completed) should be entered
    R3.                                                   Capital allowances should be               at Panel 13 Code V1 or V2
                                                          entered at Panel 2 under Codes             respectively.
                                                          S1, S2 or S3 as appropriate.
                                                          The aggregate of the trading loss,
                                                          plus the capital allowances


    RESIDENTIAL PROPERTY TAX -                                                                      STAMP DUTY
    Valuation Dates & Certificates of                                                               Abolition of need for Adjudication
    Clearance                                                                                       in the case of new houses

    Valuation Date 5 April 1996                     certificate procedure was enclosed with         reduce the formalities and simplify the
    The market value exemption limit for 1996       Issue 20 of                                     procedures for obtaining this stamp duty
    (valuation date 5 April) is £101,000            Tax Briefing.                                   exemption.
    The Income exemption limit for 1996 is          Further information may be obtained from
    £30,100.                                        the                                             The requirement to present the deed for
                                                    Capital Taxes Branch,                           impression of the PD (Particulars Delivered)
    Residential Property Tax in respect of the      Dublin Castle,                                  stamp will not be affected by the above
    valuation date 5 April 1996, is payable on      Dublin 2.                                       provisions.
    or before 1 October 1996.
                                                    Telephone No. (01) 679 2777
    Certificate of Clearance                        Extns: 4164, 4173, 4174.
    Practitioners are reminded that any person
    who purchases a residential property for an
    amount in excess of the market value
    exemption limit must deduct the specified
    amount from the sale consideration unless       New houses with a floor area of less than
    the vendor produces a Residential Property      125 square metres are exempt from stamp
    Tax clearance certificate before the sale is    duty. However, the deed of
    closed.                                         transfer/conveyance must be submitted for
    A guarantee given by the vendor (or his/her     adjudication to the Revenue Commissioners
    agent) that the clearance certificate will be   together with a floor area certificate issued
    furnished on a date subsequent to the date      by the Department of the Environment.
    of the closing of the sale does not obviate     The Finance Bill, 1996, will provide that
    the purchaser‟s obligation to deduct the        such deeds need no longer be presented for
    specified amount.                               adjudication if the deed itself contains a
                                                    statement to the effect that a valid
    Further Information                             Department of the Environment certificate
    A leaflet (RP5) outlining the main features     was in force for the new house at the date of
    of the Residential Property Tax clearance       transfer/conveyance. This measure will


    Capital Acquisitions Tax
    New Forms and Guide
    As part of the ongoing review of the
    main forms in use for Capital
                                                  Indexation Factors                                                        The indexed class thresho
                                                                                               In the meantime, if practitioners have
    Acquisitions Tax purposes, a number                                                                           new forms they
                                                                                               any queries on the Relationship
                                                  aggregation and go over the operation
    of new forms and a new guide will be                                                       should contact Capital Taxes                                    19
                                                  of the main CAT reliefs relating to
    available from mid-April.                                                                  Division‟s Taxpayer Advisory Service
                                                  agricultural and business property.
    These are                                                                                  at the numbers below. son/daughter/parent*
                                                                                                          A       e.g.                                      £174
          the standard Gift/Inheritance
                                                  Dublin:                                                  B         e.g. niece/nephew/brother/               £23,
          Tax Self-Assessment Return                                                           The new forms and guide can be
                                                  Jurys Hotel, Ballsbridge                                           sister/ grandchildren
          (IT38)                                                                               ordered (preferably by fax) from
          the Guide to completing the Self-                                                                C         e.g. strangers/cousins                   £11,
                                                  Tuesday 7 May            2.30 p.m.
          Assessment Return (IT39),                                                            Taxpayer Advisory Service
                                                                                                            In the case of a gift a parent falls into Class B
    and                                                                                        Capital Taxes Division,
          supplementary claim forms for                                                        Dublin Castle,         In relation to Probate Tax, th
                                                  Castletroy Park Hotel
          the two main CAT reliefs;                                                            Dublin 2.
                                                                                                                                  exemption thresholds
          Agricultural Relief (IT41) and
                                                  Wednesday 24 April        2.30 p.m.                            Year         Index Factor
          Business Relief (IT5)                                                                Telephone:       (01) 679 2777
                                                                                                                 1993                   –
                                                                                                       Extns. 4591/4593/4597
                                                  Cork:                                                          1994                 1.015
                                                  Silver Springs Hotel                         Fax:              1995
                                                                                                               (01) 679 3261          1.039
    A series of seminars will be held                                                                            1996                 1.065
                                                  Thursday 25 April        2.30 p.m.
    shortly at the following venues to                                                         or from
    acquaint practitioners with the new                                                                A copy of the new Statement of Practice is avai
                                                  Galway:                                              Taxpayer Advisory Service (address and phone
                                                                                               Revenue Forms Leaflets Service
    forms. The seminars will also examine
                                                  Corrib Great Southern Hotel
    the more difficult aspects of CAT such
    as                                                                                         Telephone              (01) 8780100
                                                  Tuesday 30 April         2.30 p.m.
                                                                                               (This service is available 24 hours a
                                                  Practitioners are invited to attend at the
                                                  most convenient location.

    A new Statement of Practice (SP-CAT1/96)
     detailing the index factors to be used in
    calculating CAT and Probate Tax liabilities
     up to and including 1996 is now available.

    For CAT purposes, in respect of taxable
    gifts/inheritances taken in the following
    years, the index factors to be used are:

    1990               1.04 }
    1991               1.076 } To be
    1992               1.109 } applied to
    1993               1.145 } the
    1994                     } threshold
    (prior to 11 April) 1.160 } amount

    1994                      }   To be
    (on or after 11 April)1.160    } applied to
    1995              1.188 }     the class
    1996              1.217 }     threshold


    Payment by Direct Debit
    Preliminary Tax
    Legislation                                    Completion and return of a direct debit      out above. Such applications should be
                                                   mandate form is required from any            made to the Central Services Area of the
    Section 31 Finance Act 1995 makes              customer wishing to participate in the       Collector-General‟s Office (address
    provision for the payment of Income            scheme.                                      below) and should include an
    Tax Preliminary Tax by direct debit.                                                        explanation of the reason for the change
                                                   Completed mandate forms should be            of the mandated amount.
                                                   returned to the Collector-General by the
    Minimum amount payable                         1st of the month preceding the month in
                                                   which deductions are to commence e.g.        Subsequent Years
    The minimum amount of preliminary              if deductions are to commence in
    tax which must be paid is the lower of:        February, the mandate form should be         Once a customer has joined the direct
                                                   returned by 1 January. Payments will be      debit scheme, deductions will continue
         90% of the tax liability for the actual   deducted on the 9th of each month up         to be made in accordance with the most
         year of assessment                        to and including December.                   up to date instructions provided by the
    or                                                                                          customer for subsequent years, unless
                                                                                                the customer notifies the Collector-
         100% of the tax liability for the         Cut-off Date for 1996/97 Preliminary         General that participation in the direct
         previous year of assessment               Tax                                          debit scheme is being ceased.
         in the case of direct debit               As a special transitional measure for
         participants only, 105% of the tax        1996 (in respect of Preliminary Tax for      Enquiries
         liability for the pre-preceding year      the 1996/97 year of assessment),
         of assessment.                           authorisations for the payment of            Further information on the scheme and
                                                   Preliminary Tax by direct debit will be      mandate forms may be obtained by
    * The 105% rule does not apply where           accepted by the Collector-General up to      calling
    the income tax payable for the pre-            1 June 1996.                                 (061) 310310
    preceding year is Nil.                                                                      and asking for the Direct Debit Helpline
                                                   For 1997 and subsequent years,               or by writing to
                                                   authorisations for the payment of
    Direct Debit Scheme                            Preliminary Tax by direct debit must         Office of the Collector-General,
                                                   reach the Collector-General by 1 March       Sarsfield House,
    The direct debit scheme for Preliminary        in the calendar year in which deductions     Francis Street,
    Tax is designed to spread the burden of        are to be made.                              Limerick.
    payment of preliminary tax evenly                                                           A Statement of Practice on the
    throughout the calendar year. Payments                                                      operation of the direct debit scheme is
    made in the calendar year will be              Revision of monthly payment amount           enclosed with this issue.
    credited against the Preliminary Tax
    which falls due in that calendar year. For     The amount of Preliminary Tax to be
    example, direct debit deductions made          debited on a monthly basis may be
    during 1996 will be credited against the       revised downwards at any time.
    Preliminary Tax payment due in 1996            For 1996, the first year of operation of
    for the 1996/97 year of assessment.            the scheme, upward revisions of the
                                                   monthly payment amount can be made
    At the end of the calendar year, each          up to 1 August 1996.
    customer participating in the direct debit     For 1997 and subsequent years, upward
    scheme will be issued with a statement         revisions of the monthly payment
    of all preliminary tax payments made           amount can be made up to 1 May.
    during the calendar year.                      To revise the amount of the direct debit,
                                                   a new completed mandate form,
                                                   indicating the new monthly deduction
                                                   amount, should be returned to the
                                                   Collector-General by the appropriate
                                                   Where special circumstances arise (e.g.
                                                   cessation or change in the accounting
    Participation in the Direct Debit              date for the business) the Collector-
    Scheme                                         General will consider, on an individual
                                                   basis, applications to increase the
                                                   amount of direct debit after the dates set


    Issue of Third Party Returns
    to be reduced
    Forms 46G and 46G(Company) are                  This will be reflected in the issue of            Returns are required in respect of
    currently issued to all cases on                Forms 46G in April 1996 for the year              persons who are ordinarily resident in
    Revenue records considered likely to            1995/96, where the numbers to be                  the State. Payments for services
    be required to make returns of                  issued will be reduced. They will issue           rendered by a foreign supplier who has
    payments for services.                          to the bigger cases only. Taxpayers               no presence in the country need not be
                                                    who have made returns for prior years             returned e.g. a foreign transport
    Since the introduction of automatic             and do not get one for 1995/96 are not            company delivering a machine.
    filing of Third Party returns we have           expected to file a return for 1995/96.
    received a significant amount of                Where, exceptionally, we require a                VAT exclusive figures should be given
    information which has been valuable in          return from such a taxpayer we will ask           except where a person is not registered
    Revenue programmes. We have started             for it.                                           for VAT. Where there are difficulties in
    the process of carrying out computer                                                              isolating the VAT exclusive figure, the
    analysis to identify taxpayers not on           Taxpayers who have never been issued              VAT inclusive figure will be accepted
    record and sources not returned.                with the form or who have not made                once it is made clear that it is VAT
    Having analysed returns received, we            returns for prior years should review             inclusive. The same limit of £3,000
    are getting a clearer picture of areas          their records to establish whether or             applies whether the payments are
    where we are getting relevant returns.          not they are obliged to file a return, as         returned on a VAT inclusive or
                                                    the self assessment basis applies.                exclusive basis.

                                                         leave period abroad should be             (PAYE) Allowance was extended to
    Overseas duties and Car                              excluded) - a day for this purpose        foreign social security pensions received
    Benefit-in-Kind                                      must include an overnight stay            by Irish residents from EU Member States
                                                                                                   notwithstanding that they have not been
    A car provided to a director or an                   the director/employee travels abroad      subject to a PAYE type system of tax
    employee will not be regarded as available           without the car                           deduction.
    for private use for that part of the year in
    which the director or employee is outside            the car is not available for use by the
    the State for the purpose of performing the          director‟s/ employee‟s family or
    duties of the office or employment.                  household during the
                                                         director‟s/employee‟s period of
    This treatment will apply for 1994/95                absence outside the State.
    and following years provided the following
    conditions are satisfied

          the director or employee does not
          claim the „foreign earnings
          deduction‟ (if any)under Section 154
          Finance        Act 1994 (as amended)
          in respect of the carbenefit-in-kind

                                                   PAYE Allowance
          the aggregate number of days spent       Employee (PAYE) Allowance
          outside the State for the purpose of     Section 138B, Income Tax Act 1967
          performing the duties of the office or
          employment is at least 30 complete       With effect from 1994/95 (i.e. with effect
          days in the tax year (any holiday        from the 6 April 1994), the Employee


    Urban Renewal Relief -
    Multi-storey Car Parks
    Introduction                                                                                       still has a 25 year “life” for the purposes of
                                                    It is not necessary that the multi-storey          industrial buildings allowances. There is no
    Section 41B, Finance Act 1994 (introduced       car park be located in an area                     prohibition on the granting of a balancing
    by Section 35, Finance Act 1995), extends       designated for Urban Renewal.                      allowance after the expiry of the 13 year
    the 1994 Urban Renewal provisions to                                                               period.
    certain multi-storey car parks. This article    The question of whether to issue a
    gives details of the incentives available for   certificate is one for the appropriate local       Double Rent Deduction
    expenditure on the construction or              authority to which any queries on the
    refurbishment of a multi-storey car park.       certification process should be directed.          A double rent deduction, for which Section
                                                                                                       42, Finance Act 1994 makes provision, is
    Definition of a Qualifying Multi-storey         The certificate will take the form of a letter     available to the lessee of a multi-storey car
    Car Park.                                       from the local authority to the developer. It      park, subject to the usual conditions, i.e.
                                                    will confirm that the car park has been
    In order to qualify for the incentives a        developed in accordance with the criteria                construction or refurbishment
    multi-storey car park must:                     laid down by the Minister. (Guidelines on                expenditure, which is capital in
                                                    these criteria are available from the                        nature, must be incurred on a
          be certified by the local authority in    Department of the Environment.)                              qualifying building in the three
          whose functional area the car park is                                                              year qualifying period
          located                                   The Incentives
                                                                                                             the lease under which the rent is paid
          consist of two or more stories, and       Capital Allowances                                       must be entered into during the three
          those two or more stories must be                                                                  year qualifying period
          used exclusively for the provision of     50% of expenditure incurred in the
          car parking space to members of the       qualifying period on construction or                     the lease under which the rent is paid
          public generally.                         refurbishment of a qualifying multi-storey               must be on bona fide commercial
                                                    car park qualifies for industrial buildings              terms.
    A car park located over a commercial            allowances. The rates are:
    premises, such as ground floor retail units                                                              the lessor and lessee must not,
    or offices, will qualify once it meets the      Owner-occupier:                                          directly or indirectly, be connected
    conditions outlined above. In such              50% free depreciation, or                                with each other.
    circumstances, only the expenditure on the      25% initial allowance and 2% annual
    car park will qualify for the incentives. The   allowance on the remaining 25%,                    Qualifying Period
    expenditure on which relief is being
    claimed must be apportioned so as to            Lessor:                                            The legislation runs for the three year
    exclude the expenditure on the commercial       25% initial allowance and 2% annual                period from 1 July 1995 to 30 June 1998.
    premises.                                       allowance on the remaining 25%.

    The Certification Process                       Expenditure on the refurbishment of an
                                                    existing multi-storey car park will qualify for
    In order to qualify for the incentives, the     capital allowances only if it amounts to 20%
    developer of a multi-storey car park must       or more of the market value of the car park
    obtain a certificate from the local authority   prior to refurbishment.
    in whose functional area the car park is
    located, certifying that it has been
    developed in accordance with criteria laid      Balancing Charge
    down by the Minister for the Environment.       Where an event which would otherwise give
                                                    rise to a balancing charge occurs, in the case
                                                    of a qualifying building, no balancing charge
                                                    can be imposed where the event occurs more
                                                    than 13 years after:
    These criteria relate to:                              the building is first used in the case of
                                                           construction expenditure
          planning and design,                      or
          traffic and parking anagement                    the incurring of the expenditure in the
          policies, and                                    case of refurbishment.
          pricing structures and hours of           Notwithstanding this restriction on the
          operation.                                imposition of a balancing charge the building

    Credit Unions
    Deposit Accounts and DIRT
    We have been asked to comment on             industrial and provident societies being
    the treatment of credit unions under         bodies corporate would, but                  Since credit unions are not companies
    the DIRT provisions. The position is as      for section 43 be within the charge to       which are within the charge to
    follows:                                     corporation tax).                            corporation tax in respect of relevant
                                                                                              interest, they cannot
    Under section 43 Finance Act 1972,           Relevant interest within the meaning of
    credit unions are exempt from income         Chapter IV of Part 1 Finance Act 1986             operate DIRT free deposit accounts
    tax with effect from the date of their       received by credit unions is subject to           under section 37B Finance Act 1986,
    registration under the Industrial and        DIRT.                                             or
    Provident Societies Acts 1893 to 1978.
    Section 11(6) Corporation Tax Act                                                              have DIRT refunded to them (section
    1976 extends this exemption to                                                                 35(1)(b) Finance Act 1986).
    corporation tax (registered


                                                                                                       entitled to claim a deduction
    Conacre Letting                              A number of enquires have been                        equivalent to the market value of
                                                 received from practitioners regarding                 the stock in computing the
    Income from Conacre Letting
                                                 the valuation of stock of a farming                   trading profits.
    A number of enquiries have been              trade
    received from practitioners on the tax             in the hands of the farmer who is         Note
    treatment of income from conacre                   retiring                                  This article clarifies the operation of
    letting, and whether it is chargeable              in the hands of the                       Section 62 as it stands and is without
    under the rules of Case I or Case V of             successor/transferee                      prejudice to any changes which may
    Schedule D.                                                                                  arise in this years Finance Act.
    The Revenue Approach
                                                 Where stock
    Income arising from conacre letting is “a        is sold for valuable consideration
    payment in the nature of rent”, and              to a trader
    comes within the definition of rent in       and
    Section 80(I), Income Tax Act, 1967, it          the trader is entitled to deduct
    is therefore chargeable under the rules of
                                                     that cost in computing his/her
    Case V of Schedule D .
    This approach is supported by the case
    of Maurice E. Taylor (Merchants) Ltd.        the stock should be valued at the sale
    v. Commissioner of Valuation [1981]          price or the value of the consideration
    N.I. 236. The modern conacre agreement       given. (Section 62(1)(a) Income Tax
    is analogous to a lease and consequently     Act, 1967 applies)
    any payment made on foot of that             Sales or transfers at gross under-value
    agreement is analogous to rent, i.e. a       or over-value do not come within this
    payment in the nature of rent.               provision and in such circumstances
                                                 stock should be valued at market value
    Such income should not be included in        in the hands of both the transferor and
    arriving at the Case I profit (or loss)      transferee.
    from farming, and cannot be taken into       Where stock is transferred for no
    account for the purposes of stock relief
                                                 consideration i.e. from a parent to a
    or income averaging. A separate Case V
                                                 child who is farming or commencing to
    computation is required.
    Stock Valuations on
    Farm Retirement                                    the stock should be valued at
                                                       market value in the parent‟s
    Scheme                                             accounts Section 62(1)(b)
                                                       Income Tax Act, 1967 applies)
                                                       the child, who in effect has
    Farm Retirement Scheme                             received a gift and has
    Valuation of Stock                                 appropriated it to trading stock, is


Stock Relief for Young
Farmers in Partnerships
                                             A and B farm in partnership, sharing        Practitioners should note that the
Section 21, Finance Act 1995,                profits and losses equally. B, who is 30    questions of whether a partnership
introduced a scheme of 100% stock            years of age, completed a recognised        exists in any particular case, or what
relief for farmers who are eligible for a    agricultural course in 1994, and is         the profit sharing ratios of any
grant under the EU Scheme of                 entitled to 100% stock relief by virtue     partnership are, are questions of fact.
Installation Aid for Young Farmers or        of Section 21. A, his father, is entitled   “Partnership” cases where the
who are under a certain age and have         to the usual 25% stock relief. Results      enhanced relief is claimed and it
completed a recognised agricultural          for the year ended 31 March 1996            appears that:
course. A farmer who qualifies for this      (basis period for 1995/96) show:
enhanced relief can avail of it for a                                                          a partnership does not exist,
maximum period of 4 years.                   Profit per accounts              15,000     or
A number of enquiries have been                                                                the profit sharing ratios are not
received on how the relief should be         Adjustments for light, heat,                      factual and appear to have been
ascertained in the case of a partnership.    depreciation, motor, etc.        5,000            altered so as to maximise the
In particular, where one or more of the                                                        enhanced relief for the period
partners is a “qualifying farmer” (as        Adjusted profit before                            that it is available
defined), and one or more is not.            stock relief:                    20,000
                                                                                         may be subject to audit for any year
                                             Closing stock :                  75,000     that the enhanced relief is claimed.
General                                      Opening stock:                   51,000
                                             Stock increase:                  24,000
Stock relief is a deduction in arriving at
the Case I profit. In the case of a          Allocated to A:                  12,000
partnership the practice has been to         Allocated to B:                  12,000
deduct the stock relief due in arriving at
the partnership profit. This practice will   Partner A‟s share                10,000
continue where all the partners come         less stock relief:
within the same stock relief regime.         Stock increase of
Where some partners in a partnership         £12,000 @ 25%                    3,000
are entitled to 100% stock relief while      Case I profit - A                7,000
others are entitled to the usual 25%
relief, the partnership profit to be         Partner B‟s share                10,000
allocated in accordance with the profit      less stock relief:
sharing ratios is the profit before stock    Stock increase of
relief but after making all other            £12,000 @ 100%                   12,000
adjustments. To arrive at the assessable     Case I profit - B                 Nil
profit of each partner, the stock            (stock relief cannot
increase will be allocated in accordance     create a loss)
with the profit sharing
ratios and stock relief will be allowed

Example                                      Conclusion


    Losses arising on disposal
    of BES shares
    A number of enquiries have been                the amount by which the
    received from practitioners as to how          deductions exceed the                      Allowable deduction          £10,000
    losses arising on the disposal of BES          consideration.
    shares are to be calculated.                                                              Reduce Allowable deduction by the
                                               The effect of this restriction is that the     lower of :-
    Section 25 Finance Act 1984 provides       result for Capital Gains Tax will
    that for the purposes of calculating       normally be no gain/no loss.                   the amount by which
    capital gains tax, the full acquisition                                                   the deductions exceed
    cost, indexed for inflation, may be        Example:                                       the consideration            £4,000
    deducted from the sale proceeds.           An amount of £10,000 was invested in
                                               a BES Scheme and income tax relief             the amount of the
    However, if a loss arises on a disposal    was granted as follows:                        income tax
    of shares in respect of which BES relief   £10,000 @ 48% = £4,800.                        relief allowed               £10,000
    was allowed, and not withdrawn i.e.        Seven years later the shares were sold
    where the amounts normally allowable       for £6,000.                                    (Reduction is               £4,000)
    as deductions exceed the                                                                  Allowable deduction
    consideration, then the following                                                         is now                     £6,000
    provisions will apply :                                                                   Therefore the
                                                                                              Chargeable Gain/Allowable Loss
    The amount of the deductions will be                                                      is                         Nil
    reduced by the lower of
        the amount of the income tax relief                                                   NO ALLOWABLE LOSS
        obtained (i.e. the amount of relief    The loss is calculated as follows:
        allowed, not the tax saved)
    or                                         Sale proceeds                     £6,000

    Disposal of Certain Assets in excess of £100,000
    The purpose of this article is to alert          situations which rank as                 1995 a purchaser involved in such a
    practitioners to the significant changes         disposals for C.G.T. purposes            transaction and to whom the vendor
    introduced by Section 76 Finance Act             where consideration passes               has not given a certificate is now
    1995,                                            without an asset being acquired          obliged within seven days of the time
    regarding the disposal of certain                i.e. liquidations and loan               of the acquisition to notify the
    assets for consideration in excess of            redemptions.                             Revenue Commissioners in writing,
    £100,000. These changes are effective                                                     providing particulars
    from 2 June 1995.                          C.G.50 Certificate                             of

    Paragraph 11 Schedule 4 Capital            One of the grounds on which a vendor           (Continued on page 13)
    GainsTax Act 1975 provides that on         can claim entitlement to a C.G.50 has
    the payment of consideration for           been altered. Whereas previously a
    acquiring certain assets a deduction of    vendor who satisfied the Inspector that
    15% is to be made by the purchaser,        he/she is „ordinarily resident‟ was
    unless the Inspector of Taxes has          entitled to a certificate, a vendor must
    issued a certificate relieving the         now satisfy the Inspector that he/she is
    purchaser of his/her obligation to make    „resident‟ within the meaning of
    this deduction.                            Section 150 F.A.1994.

    Assets                                     The other grounds for obtaining a
                                               certificate remain unaltered so that the
    Section 76 extends the scope of the        vendor is still entitled to a certificate if
    assets to which Paragraph 11 now           he/she can show that either no amount
    applies to include :                       of C.G.T. is payable or that the C.G.T.
                                               has been paid.
          shares received in exchange for
          shares which were of a type          Non Monetary Consideration
          specified in the original
          enactment.                           The provisions relating to non-
                                               monetary consideration disposals have
                                               been altered substantially. Since 2 June
                                              Administration of Capital Gains
     the asset acquired                       Tax
                                              There appears to be confusion among
     the consideration for acquiring the      some practitioners, especially               It is administered by the Office of the
     asset                                    solicitors, regarding the administration     Chief Inspector of Taxes in the Tax
                                              of Capital Gains Tax. This has led to        Districts spread around the country.
     the market value of the consideration    many queries being misdirected with
     and                                      consequent inefficiencies for both           Accordingly, practitioner queries (both
                                              Revenue and practitioners and their          oral and written) on behalf of clients in
       the name and address of the person     clients.                                     relation to Capital Gains should be
       making the disposal .                                                               addressed to the Tax District where the
                                              Capital Gains Tax is not administered        clients‟ Income Tax/Corporation Tax
    The purchaser must also pay to the        centrally in Dublin Castle like other        affairs are dealt with.
    Collector General 15% of the market       capital taxes such as Capital
    value of the consideration.               Acquisitions Tax.


    New Look to Form P35
    Tips for Completion

    By now each registered employer
    should have received their 1995/96 P35
    stationery. Practitioners are reminded
    that the deadline for submission of             return the original form (not a
    fully completed returns is 30 April             photocopy). In the interests of
    1996. Returns should be sent to the             accuracy the computer                        ensure that the Declaration Form
    Employers (P35) Unit, Government                technology used by Revenue to                is signed.
    Offices, Nenagh, Co. Tipperary.                 process returns is designed to
                                                    operate with original forms.                 record the correct RSI number
    In an effort to improve customer                                                             for each employee on the P35L.
    service to both taxpayers and                   use the return envelope provided
    practitioners the P35 Declaration Form          as this also speeds up processing.           make a nil return for employers
    has been redesigned and simplified                                                           who have no employees during
    thus making it easier to complete. The          ensure that all entries on the form          the tax year.
    most up to date technology is being             are complete and legible.
    used to capture and process the data on                                                The above sets out the general position.
    the new form and practitioners can              make sure that all computations        If you require further advice or
    greatly assist Revenue in achieving             are accurate and carried forward       assistance please ring the
    accurate and timely processing by               correctly.                             P35 Helpline at 6774211 (01 area)
    following some simple ground rules                                                                       or (067) 33533
    when completing the forms:-                     complete the pence boxes in the                         (all other areas).
                                                    P35 Declaration Form and ensure
         make sure that the Declaration             that the totals field (part B on the   Finally remember that employee
         Form is used only for the                  Declaration Form) is completed.        details can be submitted on
         employer to whom it is issued.                                                    Computer Tape or Diskette.
         This is necessary because each
         form is pre-coded with details
         unique to a specific employer.


                                                    Dublin PAYE No.4 District has moved           Setanta Centre,
    Tax Briefing -                                  from Hawkins House, Hawkins Street,           Nassau Street,
                                                                                                  Dublin 2.
    Issue 20                                        Dublin 2 to :

                                                    14/15 Upr. O‟Connell Street,
                                                    Dublin 1.
    Correction                                                                                    _______________________________
                                                    with effect from Monday 12 February 1996.
    Article 1.3 of Tax Briefing Issue 20, No.4,
    1995 on Off-Shore Funds contains an error.      Telephone number (01) 874 6821
                                                                                                  Revenue Forms &
    In paragraph (iv) of the Article the sentence
                                                                                                  Leaflets -
                                                    Fax number (01) 878 6389
    „Broadly, gains arising on the disposal of                                                    Centralised form
    material interests in off-shore funds after 5   This District deals with employees of:
    April 1995-----‟                                Airlines, Banks, Bookmakers, Brewers,
                                                                                                  ordering service
                                                    Dept.of Defence, Distillers, Farmers,
    should read                                     Hairdressers, Hotels, Motor Trade, National   Practitioners should note that all Revenue
                                                    Teachers, Newspapers, Printing.               forms and leaflets can now be ordered by
    „Broadly, gains arising on the disposal of                                                    telephone from
    material interests in certain off-shore funds
    after 5 April 1990-----‟                        Dublin Audit No.3 District has moved          Revenue Forms & Leaflets Service
                                                                                                  at                 (01) 878 0100
                                                    from Clanwilliam Court, Mount Street
                                                    Lower, to:                                    (This service is available 24 hours a day)
    Collector General’s                                                                           Capital Taxes
                                                    Hawkins House,
    Decentralisation                                Hawkins Street,
                                                                                                  Practitioners should also note that Capital
                                                    Dublin 2.
                                                                                                  Tax forms relating to Capital Acquisitions
                                                                                                  Tax, Stamp Duty and Residential Property
    As part of the Government‟s                     with effect from Monday 12 February 1996.
                                                                                                  Tax can also be ordered directly (preferably
    decentralisation programme, the Big Cases
                                                                                                  by Fax) from :
    Section of the Collector-General‟s Office,      Telephone number      (01) 677 5004
    formerly located in St. Martin‟s House,
    Waterloo Road, Dublin 2, has with effect        Fax number            (01) 677 5003           Taxpayer Advisory Service,
                                                                                                  Capital Taxes Division,
    from 1 March 1996 commenced relocating
                                                    This District deals with Audit and Vat        Dublin Castle,
                                                    queries of Professionals & Related            Dublin 2.
    Office of the Collector-General,                Companies.
                                                                                                  Telephone No.       (01) 679 2777
    Customer Services - Big Cases Section,
                                                                                                             Extns. 4591/4593/4597
    Sarsfield House,                                Castlebar District
                                                                                                  Fax No.             (01) 679 3261
    Francis Street,
    Limerick.                                       To avoid the possibility of correspondence
                                                    going, in error, to other offices in the
                                                    building, all correspondence for Castlebar
    Telephone No.          (061) 310310 (Dublin     District should be addressed to :-
    callers may contact this Office at
    (01) 6774211)                                   Inspector of Taxes,
                                                    Michael Davitt House,
    Fax No.               (061) 401009              Castlebar,
                                                    Co. Mayo.
    Please note that all returns and payments
    should continue to be submitted to the          Tax Briefing
    address printed on the return form.
                                                    available on diskette
                                                    Practitioners should note that Tax Briefing
                                                    can now be supplied on 3½ “diskettes, to
                                                    practitioners using Microsoft Word,
    Change of addresses                             Version 6.0. Requests should be made to :

    for                                             Tax Briefing Mailing List,
                                                    Office of the Chief Inspector of Taxes,
    Tax Districts                                   Customer Services Unit,
                                                    4th Floor,
                                                  The Revenue Commissioners will shortly
New Procedures in the                             introduce a scheme whereby repayments of           It incorporates a simplified form of
Stamp Duty Public Office,                         VAT will be made by electronic                     accounts.
                                                  transmission to bank or building society
Dublin Castle                                     accounts nominated by traders. An advice
                                                  slip giving brief details of the repayment
Following a review of cash handling                                                                  Revenue -
                                                  will be issued to traders at the same time as
arrangements in the Stamp Duty Public
                                                  the electronic payment is being made.
Office, Dublin Castle, new procedures have                                                           on the Web
been introduced with effect from 5
                                                  All traders registered for VAT have recently
February 1996. From that date, all cash                                                              People at home and abroad now have an
                                                  received an information leaflet outlining the
payments for Stamp Duty or Companies                                                                 opportunity to obtain relevant and timely
                                                  scheme and requesting details of the
Capital Duty must be made directly to :                                                              tax and customs information at the click of
                                                  nominated account to which their
                                                                                                     a mouse.
                                                  repayments will be sent.
Cash Office,
Capital Taxes Division,                                                                              Information on business incentive schemes
                                                  Electronic transmission is the quickest and
Stamping Building,                                                                                   - the 10% Corporation Tax rate, the
                                                  safest way to receive your VAT refund and
Dublin Castle,                                                                                       International Financial Services Centre and
                                                  practitioners are asked to ensure that their
Dublin 2.                                                                                            Section 35 Film Relief is now available on
                                                  clients have notified the Collector Generals
                                                                                                     the Revenue Commissioners Web site on
                                                  Office of the relevant details.
An explanatory leaflet is available from :                                                           the Internet. This site can be found at
                                                  Any further information in relation to the
Stamp Duty Office,
                                                  scheme can be obtained from:
Dublin Castle,                                                                                       For those interested in getting more
Dublin 2.                                                                                            information on these incentive schemes the
                                                  VAT Repayments Section,
                                                                                                     E-mail address is
                                                  Office of the Collector General,
For further information contact Brendan                                                    
                                                  Sarsfield House,
Costigan at (01) 679 2777 Ext: 4574 or
                                                  Francis Street,
Donal Savage at Ext: 4567.                                                                           Other information available includes the
                                                                                                     Taxpayers Charter of Rights, Personal Tax
Agents’ File                                      Tel. No. (061) 310310
                                                                                                     information, information on Double
                                                                                                     Taxation agreements, and recent changes
                                                  Fax No. (061) 401013.
Change of name or                                                                                    announced in the Budget.
Name and address information relating to          Tax Calendar 1996/97
practitioners has now been extracted from
our computer records and used to compile
a comprehensive Agents‟ File. As a result,        A tax calendar, covering the period 1 April
any changes of agent‟s name or address            1996 to 30 April 1997, is enclosed with this
will need only be notified once to a central      issue. This is a quick reference guide to remind
area and individual notifications for each        you of key tax dates in the coming tax year.
client to various districts and offices will no
longer be necessary.
Changes of agents name/address should be
notified to:

Taxes Central Registration Office,
Arus Brugha,
9/10 Upper O‟Connell St,
Dublin 1.

Telephone No.          (01) 874 6821
Fax No.                (01) 874 6078
                                                  New Business Profile
                                                  Form (Form BP1)
                                                  A new simplified tax return form is being
Electronic                                        introduced on a trial basis for the 1995/96
transmission of VAT                               tax year to cater for small unincorporated
                                                  businesses which do not engage agents to
repayments                                        prepare their tax returns. The form,
                                                  Business Profile (Form BP1), is similar to
                                                  the Farm Profile (Form AG12) currently
                                                  used by certain farmers.
Double Taxation Treaties entered into by Ireland
     COUNTRY       DATE OF SIGNING          DATE OF                                  DATE OF ENTRY INTO EFFEct
                                                                   Income Tax      Corporation Tax       Capital Gains Tax      S.I. No.
 AUSTRALIA         31 May 1983         21 December 1983           6 April 1984     1 January 1984          6 April 1984       406 of 1983
 AUSTRIA           24 May 1966         5 January 1968             " " 1964                                                    250 of 1967
 AUSTRIAN          19 June 1987        9 December 1988            " " 1976         1 January 1974          6 April 1974        29 of 1988
 BELGIUM           24 June 1970        31 December 1973           "   "   1973                                                 66 of 1973
 CANADA            23 November 1966    6 December 1967            "   "   1958                                                212 of 1967
 CYPRUS            24 September 1968   4 December 1970            "   "   1952                                                 79 of 1970
 CZECH REPUBLIC    14 November 1995    IR - December 1995                                                                     321 of 1995
 DENMARK           26 March 1993       8 October 1993             "   "   1994     1 January 1994          6 April 1994       286 of 1993
 FINLAND           27 March 1992       26 November 1993           "   "   1990     1 January 1990          6 April 1990       289 of 1993
 FRANCE            21 March 1968       15 June 1971               "   "   1966                                                162 of 1970
 GERMANY           17 October 1962     2 April 1964               "   "   1959                                                212 of 1962
 HUNGARY           25 April 1995       IR - December 1995                                                                     301 of 1995
 ITALY             11 June 1971        14 February 1975            " " 1967                                                    64 of 1973
 ISRAEL            20 November 1995       December 1995            " " 1996        1 January 1996          6 April 1996       323 of 1995
 JAPAN             18 January 1974     4 November 1974             " " 1974                                                   259 of 1974
 KOREA (REP. OF)   18 July 1990        27 November 1991            " " 1992        1 January 1992          6 April 1992       290 of 1991
 LUXEMBOURG        14 January 1972     25 February 1975            " " 1968                                                    65 of 1973
 NETHERLANDS       11 February 1969    12 May 1970                 " " 1965                                                    22 of 1970
 NEW ZEALAND       19 September 1986   26 September 1988           " " 1989        1 January 1989          6 April 1989        30 of 1988
 NORWAY            21 October 1969     21 August 1970              " " 1967                                                    80 of 1970
 PAKISTAN          13 April 1973       20 December 1974            " " 1968                                                   260 of 1974
 POLAND            13 November 1995       December 1995            " " 1996         1 January 1996         6 April 1996       322 of 1995
 PORTUGAL          1 June 1993         11 July 1994                " " 1995         1 January 1995         6 April 1995       102 of 1994
 RUSSIA            29 April 1994         7 July 1995               " " 1996         1 January 1996         6 April 1996       428 of 1994
 SPAIN             10 February 1994    21 November 1994            " " 1995         1 January 1995         6 April 1995       308 of 1994
 SWEDEN            8 October 1986      5 April 1988                " " 1988         1 January 1989         6 April 1988       348 of 1987
 SWEDISH           1 July 1993         21 December 1993          20 January 1994   20 January 1994       20 January 1994      398 of 1993
 SWITZERLAND       8 November 1966     16 February 1968           6 April 1965                                                240 of 1967
 SWISS PROTOCOL    24 October 1980     25 April 1984              " " 1976         1 January 1974          6 April 1974        76 of 1984
 UNITED KINGDOM    2 June 1976         23 December 1976           " " 1976         1 January 1974          6 April 1976       319 of 1976
 UK PROTOCOL       7 November 1994     21 September 1995          6 April 1994       1 April 1994                             209 of 1995
 UNITED STATES     13 September 1949   20 December 1951           " " 1951                                                   Sch. B, ITA „67
 ZAMBIA            29 March 1971       31 July 1973               " " 1967                                                    130 of 1973

 SOUTH AFRICA      1 May 1958          26 August 1960                                                                         210 of 1959
 SPAIN             25 February 1975    25 March 1977                               Sea or Air Transport Agreements             26 of 1977
 U.S.S.R.          17 December 1986    23 December 1987                            Air Transport Agreement                    349 of 1987


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