Finance Act , 1994

148.—Without prejudice to the meaning of section 11 of the Principal Act as enacted, that section shall have effect and be deemed always to have had effect as if the provisions of section 123 of the Finance Act, 1993, had not been enacted, except where the consideration referred to in the said section 11, being consideration in relation to a disposition, could not reasonably be regarded (taking into account the disponer's position prior to the disposition) as representing full consideration to the disponer for having made such a disposition.

PART VII Miscellaneous

Chapter I Provisions Relating to Residence of Individuals

149 Interpretation (Chapter I).

149.—In this Part—

“the Acts” means—

(a) the Income Tax Acts,

(b) the Corporation Tax Acts,

(c) the Capital Gains Tax Acts, and

(d) the Capital Acquisitions Tax Act, 1976, and the enactments amending or extending that Act,

and any instrument made thereunder;

“authorised officer” means an officer of the Revenue Commissioners authorised by them in writing for the purposes of this Chapter;

“present in the State”, in relation to an individual, means the personal presence of the individual in the State;

“tax” means any tax payable in accordance with any provision of the Acts.

150 Residence.

150.—(1) For the purposes of the Acts, an individual is resident in the State for a year of assessment if the individual is present in the State—

(a) at any one time or several times in the year of assessment for a period in the whole amounting to 183 days or more, or

(b) at any one time or several times—

(i) in the year of assessment, and

(ii) in the preceding year of assessment,

for a period (being a period comprising in the aggregate the number of days on which the individual is present in the State in the year of assessment and the number of days on which the individual was present in the State in the preceding year of assessment) in the whole amounting to 280 days or more:

Provided that, notwithstanding paragraph (b), where for a year of assessment an individual is present in the State at any one time or several times for a period in the whole amounting to not more than 30 days—

(a) the individual shall not be resident in the State for the year of assessment, and

(b) no account shall be taken of the period for the purposes of the aggregate mentioned in paragraph (b).

(2) (a) Notwithstanding subsection (1), an individual—

(i) who is not resident in the State for a year of assessment, and

(ii) to whom paragraph (b) applies,

may, at any time, elect to be treated as resident in the State for that year and, where an individual so elects, the individual shall, for the purposes of the Acts, be deemed to be resident in the State for that year.

(b) This paragraph applies to an individual who satisfies an authorised officer that the individual is in the State—

(i) with the intention, and

(ii) in such circumstances,

that the individual will be resident in the State for the following year of assessment.

(3) For the purposes of this section, an individual shall be deemed to be present in the State for a day if the individual is present in the State at the end of the day.

151 Ordinary residence.

151.—(1) For the purposes of the Acts, an individual is ordinarily resident in the State for a year of assessment if the individual has been resident in the State for each of the 3 years of assessment preceding that year.

(2) An individual who is ordinarily resident in the State shall not, for the purposes of the Acts, cease to be ordinarily resident in the State for a year of assessment unless the individual has not been resident in the State in each of the 3 years of assessment preceding that year.

152 Application of Part III (Schedule C) and section 52 (Schedule D) of Income Tax Act, 1967.

152.—(1) Where an individual is not resident but is ordinarily resident in the State, Part III and section 52 of the Income Tax Act, 1967, shall apply and have effect as if the individual were resident in the State:

Provided that this section shall not apply in respect of the income of an individual derived from one or more of the following, that is to say, a trade or profession, no part of which is carried on in the State or an office or employment all the duties of which are performed outside the State.

(2) In determining for the purposes of subsection (1) whether the duties of an office or employment are performed outside the State, any duties performed in the State, the performance of which is merely incidental to the performance of the duties of the office or employment outside the State, shall be treated for the purposes of this section as having been performed outside the State.

153 Split year residence.

153.—(1) For the purposes of a charge to tax on any income, profits or gains from an employment, where, during a year of assessment (“the relevant year”)—

(a) (i) an individual who has not been resident in the State for the preceding year of assessment, satisfies an authorised officer that the individual is in the State—

(I) with the intention, and

(II) in such circumstances,

that the individual will be resident in the State for the following year of assessment, or

(ii) an individual who is resident in the State, satisfies an authorised officer that the individual is leaving the State, other than for a temporary purpose,

(I) with the intention, and

(II) in such circumstances,

that the individual will not be resident in the State for the following year of assessment,

and

(b) the individual would, but for the provisions of this section, be resident in the State for the relevant year,

subsection (2) shall apply in relation to the individual.

(2) (a) An individual to whom paragraphs (a) (i) and (b) of subsection (1) apply, shall be deemed to be resident in the State for the relevant year only from the date of his or her arrival in the State.

(b) An individual to whom paragraphs (a) (ii) and (b) of subsection (1) apply, shall be deemed to be resident in the State for the relevant year only up to and including the date of his or her leaving the State.

(3) Where, by virtue of this section, an individual is resident in the State for part of a year of assessment, all the provisions of the Acts shall apply as if—

(a) income arising during that part of the year or, in a case to which the provisions of section 76 (3) of the Income Tax Act, 1967, apply, amounts received in the State during that part of the year, were income arising or amounts received for a year of assessment in which the individual is resident in the State, and

(b) income arising or, as the case may be, amounts received in the remaining part of the year, were income arising or amounts received in a year of assessment in which the individual is not resident in the State.

154 Deduction for income earned outside the State.

154.—(1) Where for any year of assessment an individual who is resident in the State makes a claim in that behalf to and satisfies an authorised officer that—

(a) the duties of an office or employment to which this section applies of the individual are performed wholly or partly outside the State, and

(b) either—

(i) the number of days in that year which are qualifying days in relation to the office or employment (together with any days which are qualifying days in relation to any other such office or employment of the individual), or

(ii) the number of such days as aforesaid in a relevant period in relation to that year,

amounts to at least 90 days,

there shall be deducted from the income, profits or gains from the office or employment to be assessed under Schedule D or Schedule E, as may be appropriate, an amount equal to the specified amount.

(2) In this section—

“a qualifying day”, in relation to an office or employment of an individual, is a day which is—

(a) one of at least 14 consecutive days on which the individual is absent from the State for the purposes of the performance of the duties of that office or employment or of those duties and the duties of other offices or employments of the individual outside the State and which (taken as a whole) are substantially devoted to the performance of such duties as aforesaid, and

(b) one of which the individual concerned is absent from the State at the end of the day:

Provided that no day shall be counted more than once as a qualifying day;

“relevant period”, in relation to a year of assessment, means a continuous period of 12 months—

(a) part only of which is comprised in that year of assessment, and

(b) no part of which is comprised in another relevant period;

“the specified amount” is an amount determined by the formula—

(D—N) E _____ 365

where—

D is the number of qualifying days in the year of assessment concerned,

E is all the income, profits or gains from offices or employments to which this section applies (including income from offices or employments, the duties of which are performed in the State) of an individual in that year, and

N is—

(a) if subsection (1) (b) (i) applies, 15, or

(b) if subsection (1) (b) (ii) applies, a number which bears the same proportion to 15 as the number of qualifying days in the part of the relevant period comprised in the year of assessment bears to the number of qualifying days in that relevant period.

(3) This section applies to—

(a) an office of director of a company which is within the charge to corporation tax or would be within the charge to corporation tax if it were resident in the State and which carries on a trade or profession,

(b) an employment other than—

(i) an employment the emoluments of which are paid out of the revenue of the State, or

(ii) an employment with any board, authority or other similar body established by or under statute:

Provided that this section shall not apply in any case where the income from an office or employment—

(a) is chargeable to tax in accordance with the provisions of section 76(3) of the Income Tax Act, 1967, or

(b) (i) is subject to the provisions of Part III of Schedule 6 to the Income Tax Act, 1967, or

(ii) would be so subject, if the employment were deemed to be property situated where the employment is exercised, or

(c) is income to which section 153 applies.

(4) Nothwithstanding anything contained in the Acts, the income, profits or gains from an office or employment shall, for the purposes of this section, be deemed not to include any amounts paid in respect of expenses incurred wholly, exclusively and necessarily in the performance of the duties of the office or employment.

155 Non-residents.

155.—Section 153 of the Income Tax Act, 1967, is hereby amended—

(a) in subsection (2) by the substitution of the following paragraph for paragraph (c):

“(c) that he is a citizen, subject or national of another Member State of the European Union or of a country of which the citizens, subjects or nationals are for the time being exempted by an order under section 10 of the Aliens Act, 1935, from any provision of, or of an aliens order under, that Act, or”,

and

(b) by the insertion of the following subsection after subsection (2):

“(3) Notwithstanding subsection (2), where an individual who is not resident in the State proves to the satisfaction of the Revenue Commissioners that the individual is a resident of another Member State of the European Union and that the proportion which the portion of the individual's income which is subject to Irish tax bears to the individual's total income from all sources (including income which is not subject to Irish tax) is three-fourths or greater, subsection (1) or, as the case may be, subsection (2) shall not apply to that individual and he or she shall be entitled to the allowance, deduction or other benefit mentioned in subsection (1).”.

156 Appeals.

156.—(1) An individual who is aggrieved by the decision of an authorised officer on any question arising under those provisions of this Chapter which require an individual to satisfy an authorised officer on such a question may, by notice in writing to that effect given to the authorised officer within two months from the date on which notice of the decision is given to the individual, make an application to have the question heard and determined by the Appeal Commissioners.

(2) Where an application is made under subsection (1), the Appeal Commissioners shall hear and determine the question concerned in like manner as an appeal made to them against an assessment and all the provisions of the Acts relating to such an appeal (including the provisions relating to the rehearing of an appeal and to the statement of a case for the opinion of the High Court on a point of law) shall apply accordingly with any necessary modifications.

157 Repeals.

157.—(1) Sections 76 (4), 199 and 206 of the Income Tax Act, 1967, and section 4 of the Finance Act, 1987, are hereby repealed.

(2) Where the Revenue Commissioners are satisfied that the repeal of section 76 (4) of the Income Tax Act, 1967, would give rise to hardship in the case of income derived in the manner mentioned in the said section 76 (4), they may, for the year 1994-95 and for that year of assessment only, grant such relief as in their opinion is just.

158 Commencement (Chapter I).

158.—(1) Subject to subsection (2), this Chapter shall apply as respects the year 1994-95 and subsequent years of assessment.

(2) Where in any case an individual—

(a) was resident in the State for the year of assessment 1991-92 but not resident in the State for the years of assessment 1992-93 and 1993-94, or

(b) was resident in the State for the year of assessment 1992-93 but not resident in the State for the year of assessment 1993-94, or

(c) was resident in the State for the year of assessment 1993-94 and would not, but for section 150, be resident in the State in the year of assessment 1994-95, or

(d) left the State in the years of assessment 1992-93 or 1993-94 for the purpose of commencing a period of ordinary residence outside the State and did not recommence ordinary residence in the State prior to the end of the year of assessment 1993-94,

section 150 and section 157, in so far as it relates to the repeal of section 4 of the Finance Act, 1987, shall apply as respects the year 1995-96 and subsequent years of assessment in that case.

Chapter II General

159 Capital Services Redemption Account.

159.—(1) In this section—

“the 1993 amending section” means section 135 of the Finance Act, 1993;

“capital services” has the same meaning as it has in the principal section;

“the forty-fourth additional annuity” means the sum charged on the Central Fund under subsection (4);

“the principal section” means section 22 of the Finance Act, 1950.

(2) In relation to the twenty-nine successive financial years commencing with the financial year ending on the 31st day of December, 1994, subsection (4) of the 1993 amending section shall have effect with the substitution of “£63,399,051” for “£60,543,110”.

(3) Subsection (6) of the 1993 amending section shall have effect with the substitution of “£47,996,485” for “£46,534,800”.

(4) A sum of £68,241,818 to redeem borrowings, and interest thereon, in respect of capital services shall be charged annually on the Central Fund or the growing produce thereof in the thirty successive financial years commencing with the financial year ending on the 31st day of December, 1994.

(5) The forty-fourth additional annuity shall be paid into the Capital Services Redemption Account in such manner and at such times in the relevant financial year as the Minister for Finance may determine.

(6) Any amount of the forty-fourth additional annuity, not exceeding £52,452,200 in any financial year, may be applied towards defraying the interest on the public debt.

(7) The balance of the forty-fourth additional annuity shall be applied in any one or more of the ways specified in subsection (6) of the principal section.

160 Establishment of Small Savings Reserve Fund.

160.—(1) In this section—

“the Fund” means the Small Savings Reserve Fund established by subsection (2);

“the Minister” means the Minister for Finance;

“small savings” means savings certificates (being savings to which section 30 of the Finance Act, 1940, relates), national instalment savings (being savings to which section 53 of the Finance Act, 1970, relates) and savings bonds (being savings to which section 54 of the Finance Act, 1970, relates).

(2) There is hereby established a fund, to be known as the Small Savings Reserve Fund, which shall be under the control of the Minister.

(3) The Minister shall pay into the Fund in the year 1994, the sum of £60,000,000, and in each year thereafter such sums, if any, as the Minister may decide.

(4) Where in any calendar year interest payments on encashments of small savings exceed 11 per cent. of the total interest accrued on such savings at the end of the immediately preceding calendar year, the resources of the Fund may be applied towards meeting so much of those interest payments which, as a percentage of the said total interest accrued, exceed 11 per cent.

(5) The resources of the Fund shall be made available, without payment of interest, to the Exchequer by way of repayable ways and means advances.

(6) Accounts prepared under section 12 of the National Treasury Management Agency Act, 1990, shall include an account of payments into and out of the Fund and a statement of the resources in the Fund—

(a) on the 1st day of January of the calendar year in which the financial year of the said accounts commences, and

(b) on the 31st day of December in that calendar year.

(7) The functions of the Minister referred to in the First Schedule to the National Treasury Management Agency Act, 1990, for the purposes of section 5 of that Act shall be construed as if there were included in that Schedule for those purposes a reference to the functions of the Minister under this section.

161 Securities of International Bank for Reconstruction and Development.

161.—(1) This section applies to any stock or other form of security issued by the International Bank for Reconstruction and Development.

(2) Any stock or other form of security to which this section applies shall be deemed—

(a) to be a security issued under the authority of the Minister for Finance within the meaning of section 466 of the Income Tax Act, 1967, and

(b) to be a security to which section 63 of the Finance Act, 1969, applies,

and those sections shall apply and have effect accordingly.

(3) Section 474 of the Income Tax Act, 1967, is hereby amended in subsection (1) by the insertion of “, or section 161 of the Finance Act, 1994” after “section 92 of the Finance Act, 1973”.

(4) The First Schedule (as amended by the Finance Act, 1970, and subsequent enactments) to the Stamp Act, 1891, is hereby amended by the insertion in paragraph 1 of the Heading “GENERAL EXEMPTIONS FROM ALL STAMP DUTIES” of the following subparagraph after subparagraph (ia) (inserted by the Finance Act, 1973):

“(ib) any stock or other form of security to which section 161 of the Finance Act, 1994, applies,”.

(5) Section 66 (as amended by the Finance Act, 1989) of the Finance Act, 1984, is hereby amended by the insertion after “Steel Community,” of “the International Bank for Reconstruction and Development,”.

162 Amendment of section 486 (power of Collector and authorised officers to sue) of Income Tax Act, 1967.

162.—(1) Section 486 of the Income Tax Act, 1967, is hereby amended by the substitution of the following subsections for subsections (1) and (2):

“(1) Where the amount due (whether before or after the passing of this Act) in respect of income tax does not exceed the amount which is the monetary limitation on the jurisdiction of the Circuit Court provided for in an action founded on quasi-contract at reference number 1 of the Third Schedule to the Courts (Supplemental Provisions) Act, 1961, the Collector or other officer of the Revenue Commissioners, duly authorised to collect the said tax may sue in that officer's own name in the Circuit Court for the said amount so due as a debt due to the Minister for Finance.

(2) Where the amount so due does not exceed the amount which is the monetary limitation on the jurisdiction of the District Court provided for in an action founded on contract by clause (i) of paragraph A of section 77 of the Courts of Justice Act, 1924, the Collector or other officer of the Revenue Commissioners duly authorised to collect the said tax may sue in that officer's own name in the District Court for the said amount so due as a debt due to the Minister for Finance.”.

(2) Subsection (1) shall be deemed to have come into force and shall take effect as on and from the 15th day of August, 1991.

163 Amendment of section 1 (interpretation) of Waiver of Certain Tax, Interest and Penalties Act, 1993, and related matters.

163.—(1) Section 1 of the Waiver of Certain Tax, Interest and Penalties Act, 1993, is hereby amended in paragraph (a) by the substitution in the definition of “the specified period” of “21st day of December” for “30th day of November”.

(2) As respects the year of assessment 1992-93 the following provisions of the Tax Acts shall be construed as if references in those provisions to the 31st day of January were references to the 28th day of February—

(a) section 236 (11) of the Income Tax Act, 1967,

(b) section 48 (1) (a) of the Finance Act, 1986, in subparagraph (IIa) of paragraph (i) of the definition of “specified date”, and

(c) section 9 (1) of the Finance Act, 1988, and sections 226(1) and 230(1) of the Finance Act, 1992, in the definitions of “specified return date for the chargeable period”.

(3) This section shall be deemed to have come into operation on the 14th day of July, 1993.

164 Tax treatment of expenses of members of the Judiciary.

164.—(1) In this section, “a member of the Judiciary” means—

(a) a judge of the Supreme Court,

(b) a judge of the High Court,

(c) a judge of the Circuit Court, or

(d) a judge of the District Court.

(2) An allowance payable by way of an annual sum to a member of the Judiciary in accordance with the provisions of section 5 of the Courts of Justice Act, 1953, and which has been determined, in accordance with the provisions of paragraph (c) of subsection (2) of the said section 5, by the Minister for Justice in consultation with the Minister for Finance to be in full settlement of the expenses which such a person is obliged to incur in the performance of his duties as a member of the Judiciary and which are not otherwise reimbursed either directly or indirectly out of moneys provided by the Oireachtas, shall be exempt from income tax and shall not be reckoned in computing income for the purposes of the Income Tax Acts.

(3) The provisions of rules 3 and 4 of Schedule 2 to the Income Tax Act, 1967, shall not apply or have effect in relation to expenses in full settlement of which an allowance referred to in subsection (2) is payable and no claim shall lie under those rules in respect of those expenses.

165 Care and management of taxes and duties.

165.—All taxes and duties imposed by this Act are hereby placed under the care and management of the Revenue Commissioners.

166 Short title, construction and commencement.

166.—(1) This Act may be cited as the Finance Act, 1994.

(2) Parts I and VII (so far as relating to income tax) shall be construed together with the Income Tax Acts and (so far as relating to corporation tax) shall be construed together with the Corporation Tax Acts and (so far as relating to capital gains tax) shall be construed together with the Capital Gains Tax Acts.

(3) Part II (so far as relating to customs) shall be construed together with the Customs Acts and (so far as relating to duties of excise) shall be construed together with the statutes which relate to the duties of excise and to the management of those duties.

(4) Part III shall be construed together with the Value-Added Tax Acts, 1972 to 1993, and may be cited together therewith as the Value-Added Tax Acts, 1972 to 1994.

(5) Part IV shall be construed together with the Stamp Act, 1891, and the enactments amending or extending that Act.

(6) Part V shall be construed together with Part VI of the Finance Act, 1983, and the enactments amending or extending that Part.

(7) Parts VI and VII (so far as relating to capital acquisitions tax) shall be construed together with the Capital Acquisitions Tax Act, 1976, and the enactments amending or extending that Act.

(8) Part I shall, save as is otherwise expressly provided therein, be deemed to have come into force and shall take effect as on and from the 6th day of April, 1994.

(9) In relation to Part III:

(a) paragraphs (b), (c) and (d) of section 94, section 97 and paragraphs (a) and (b) of section 101 shall take effect as on and from the 1st day of July, 1994;

(b) paragraph (a) of section 99 shall take effect as on and from the 1st day of September, 1994;

(c) section 91 shall take effect as on and from the 1st day of January, 1995;

(d) section 93 and paragraph (a) of section 96 shall take effect as on and from such date as the Minister for Finance may, by order, appoint;

(e) paragraph (b) of section 99 shall take effect as on and from the commencement of section 89;

(f) the provisions of this Part, other than those specified in paragraphs (a) to (e), shall have effect as on and from the date of passing of this Act.

(10) Any reference in this Act to any other enactment shall, except so far as the context otherwise requires, be construed as a reference to that enactment as amended by or under any other enactment including this Act.

(11) In this Act, a reference to a Part, section or Schedule is to a Part or section of, or Schedule to, this Act, unless it is indicated that reference to some other enactment is intended.

(12) In this Act, a reference to a subsection, paragraph, subparagraph, clause or subclause is to the subsection, paragraph, subparagraph, clause or subclause of the provision (including a Schedule) in which the reference occurs, unless it is indicated that reference to some other provision is intended.

FIRST SCHEDULE Amendments Consequential on Changes in Personal Reliefs

The Income Tax Act, 1967, is hereby amended in accordance with the following provisions:

(a) in section 138—

(i) in paragraph (a), by the substitution of “£4,700” for “£4,350” (inserted by the Finance Act, 1993),

(ii) in paragraph (b) (as amended by the Finance Act, 1988), by the substitution of “£2,850” and “£4,700”, respectively, for “£2,675” and “£4,350” (inserted by the Finance Act, 1993), and

(iii) in paragraph (c), by the substitution of “£2,350” for “£2,175” (inserted by the Finance Act, 1993),

and

(b) in section 138A (2) (inserted by the Finance Act, 1985), by the substitution of “£1,850” and “£2,350”, respectively, for “£1,675” and “£2,175” (inserted by the Finance Act, 1993).

SECOND SCHEDULE Exemption of Specified Non-Commercial State-Sponsored Bodies from Certain Tax Provisions

THIRD SCHEDULE Rates of Excise Duty on Tobacco Products

Description of Product	Rate of Duty
Cigarettes	£53.25 per thousand together with an amount equal to 16.83 per cent. of the price at which the cigarettes are sold by retail
Cigars	£81.702 per kilogram
Fine-cut tobacco for the rolling of cigarettes	£68.944 per kilogram
Other smoking tobacco	£56.682 per kilogram

FOURTH SCHEDULE Rates of Excise Duty on Cider and Perry

Description of Cider and Perry	Rate of Duty
Still and Sparkling:
Of an actual alcoholic strength by volume not exceeding 6 vol	£35.03 per hectolitre
Of an actual alcoholic strength by volume exceeding 6 vol but not exceeding 8.5 vol	£151.59 per hectolitre
Still:
Of an actual alcoholic strength by volume exceeding 8.5 vol but not exceeding 15 vol	£215.01 per hectolitre
Of an actual alcoholic strength by volume exceeding 15 vol	£311.97 per hectolitre
Sparkling:
Of an actual alcoholic strength by volume exceeding 8.5 vol	£430.02 per hectolitre

FIFTH SCHEDULE Rates of Excise Duty on Wine and Made Wine

Description of Wine and Made Wine	Rate of Duty
Still and Sparkling:
Of an actual alcoholic strength by volume not exceeding 5.5 vol	£71.66 per hectolitre
Still:
Of an actual alcoholic strength by volume exceeding 5.5 vol but not exceeding 15 vol	£215.01 per hectolitre
Of an actual alcoholic strength by volume exceeding 15 vol	£311.97 per hectolitre
Sparkling:
Of an actual alcoholic strength by volume exceeding 5.5 vol	£430.02 per hectolitre

SIXTH SCHEDULE Qualifications for Applying for Relief from Stamp Duty in respect of Transfers to Young Trained Farmers

(a) Certificate in Farming;

(b) Diploma in Commercial Horticulture;

(c) Diploma in Amenity Horticulture;

(d) Diploma in Pig Production;

(e) Diploma in Poultry Production.

(a) Certificate in Farm Management;

(b) Certificate in Farm Husbandry;

(c) Trainee Farmer Certificate.

(a) Degree in Agricultural Science awarded by the National University of Ireland through University College Dublin;

(b) Degree in Horticultural Science awarded by the National University of Ireland through University College Dublin;

(c) Degree in Veterinary Science awarded by the National University of Ireland through University College Dublin;

(d) Degree in Rural Science awarded by the National University of Ireland through University College Cork or by the University of Limerick;

(e) Diploma in Rural Science awarded by the National University of Ireland through University College Cork;

(f) Degree in Dairy Science awarded by the National University of Ireland through University College Cork;

(g) Diploma in Dairy Science awarded by the National University of Ireland through University College Cork.

(a) National Certificate in Agricultural Science studied through Kildalton Agricultural College and Waterford Regional Technical College;

(b) National Certificate in Business Studies (Agri-business) studied through the Franciscan Brothers Agricultural College, Mountbellew, and Galway Regional Technical College.

SEVENTH SCHEDULE Computation of Residential Property Tax

M is the market value exemption limit, and

G is the general exemption limit.

TABLE

Net Market Value	Rates
(1)	(2)
	1 per cent.
	1.5 per cent.
The remainder	2 per cent.

TABLE

Net Market Value	Tax Chargeable
(1)	(2)