Bills Digest No. 166 2001-02
New Business Tax System (Over-Franking Tax) Bill
2002
WARNING:
This Digest was prepared for debate. It reflects the legislation as
introduced and does not canvass subsequent amendments. This Digest
does not have any official legal status. Other sources should be
consulted to determine the subsequent official status of the
Bill.
CONTENTS
Passage History
Purpose
Background
Main Provisions
Concluding Comments
Endnotes
Contact Officer & Copyright Details
Passage History
New Business Tax System (Imputation)
Bill 2002
New Business Tax System (Over-Franking
Tax) Bill 2002
New Business Tax System (Franking
Deficit Tax) Bill 2002
Date Introduced: 30 May 2002
House: House of Representatives
Portfolio: Treasury
Commencement: On the day the Acts receives
Royal Assent. The measures take effect from 1 July 2002.
Purpose:
The package of Bills comprising the
New Business Tax System (Imputation) Bill 2002 (the Imputation
Bill), the
New Business Tax System (Over-Franking Tax) Bill 2002 (the
Over-Franking Tax Bill) and the
New Business Tax System (Franking Deficit Tax) Bill 2002 (the
Franking Deficit Tax Bill) introduce a new simplified imputation
system.
The Imputation Bill includes proposed measures
in three Schedules.
-
- Schedule 1 inserts proposed Part 3-6
The imputation system into the Income Tax Assessment
Act 1997 (ITAA 1997) which applies to events that occur on or
after 1 July 2002 under proposed section
201-5.
-
- Schedule 2 has consequential amendments to the
Dictionary of the ITAA 1997 and takes effect under section 2 of the
Imputation Bill when it receives Royal Assent.
-
- Schedule 3 includes transitional provisions
and provides for Part IIIAA of the Income Tax Assessment Act
1936 (ITAA 1936) which deals with the current imputation
system to cease to apply to events that occur on or after 1 July
2002.
The Over-franking Bill provides a mechanism that
ensures that companies frank distributions in accordance with the
benchmark rule.
The Franking Deficit Bill ensures that a company
makes good the over-imputation of franking credits that it makes to
its shareholders when making franked dividends to them.
In the words of the joint
Explanatory Memorandum to the three Bills (paragraph 1.18) the
changes are mainly to the mechanics of the imputation system and
not to its outcome:
Whilst the new imputation system changes the
mechanics of the current system, the new imputation provisions will
generally provide the same outcome as the current imputation
system.(1)
The Explanatory Memorandum also states that new imputation
system will have no revenue impact.(2)
The imputation system is the mechanism
in taxation law which enables income tax paid by a corporate tax
entity to be passed on to its members. It was first inserted into
tax law in 1987.(3) It is through this system that
members of a corporate tax entity obtain a credit for the
underlying company tax paid on the company profits that have been
distributed to them. This credit, called an imputation credit,
gives rise to a franking rebate. Members use this franking rebate
to reduce their income tax liability. The imputation
system prevents the double taxation of income earned and
distributed by corporate tax entities. Without the imputation
system, income tax would be levied when income is earned by the
entity and then again in the hands of the members when it is
distributed to them.
The way in which the corporate tax entity passes
the income tax paid by it to its members is by franking (in the
sense of stamping or marking) the distribution. Only frankable
distributions may be franked. In order to frank (that is, allocate
franking credits to a distribution), a corporate tax entity is
required to maintain a franking account.
The tax credits that can be imputed to members
are recorded in the entity s franking account as franking credits.
Franking credits generally reflect income tax paid by the entity,
or underlying tax paid through other corporate entities that is
imputed to it.
Subject to anti-avoidance rules, resident
individuals, superannuation entities, registered charities and
deductible gift organisations are eligible for refunds of excess
imputation credits to the extent that imputation credits exceed tax
payable by these entities.
The rules around franking a distribution and
franking accounts, and some of the anti-streaming rules, apply to
corporate tax entities only. Corporate tax entities are companies,
corporate limited partnerships, corporate unit trusts and public
trading trusts. These entities are taxed separately from their
members and are taxed at the company tax rate.
The rules on the tax effects of receiving a
franked distribution apply to all entities, including individuals,
corporate tax entities and superannuation entities.
It will be noted that corporate tax entities do
not include partnerships and trusts (which are not corporate unit
trusts and public trading trusts).
A key proposal in the
Tax Reform: not a new tax a new tax system
(4) (the ANTS package) issued by the
Government in August 1998 to ensure fairness and integrity in the
tax system with the introduction of the goods and services tax
(GST) was the implementation of a unified entity regime (UER). This
reform has been referred to by various names, including "entity
taxation", "tax entity regime" "unified entity regime" and
"consistent entity regime". The simplified imputation system, a
significant component of the UER, was to apply to all entity
distributions including trust and partnership distributions so that
the tax paid by the entity was attributed to the recipients of the
distributions.
The consequences of the differential treatment
of entities and the inconsistent treatment of distributions and the
need for reform was stated in the ANTS package as follows:
Taxation of business entities is
inconsistent
The taxation of business entities requires
reform across three key problem areas: inconsistent entity
treatment; inappropriate taxation of company groups; and
inconsistent treatment of distributions.
Different treatment of entities produces unfair
outcomes
Under current law, vastly different treatment is
accorded to investment income channelled through different
entities. The treatment is different both between the various
entities and at the individual investor (eg shareholder) level.
Companies, fixed trusts, and discretionary
trusts all offer investors the prospect of limited liability
shielding them from full personal liability for making good the
entities financial liabilities. And yet there is very different
treatment across these entities of distributions out of profits
freed from taxation by tax preferences ( tax-preferred income).
Such distributions by companies (ie franked dividends) are
taxed in the hands of individual resident shareholders. In the case
of fixed trusts these distributions are generally taxed
with a delay when the interests in the trust are sold. With
discretionary trusts the distributions are not taxed at
all. The beneficiaries of discretionary trusts enjoy the best of
both worlds , benefiting from both limited liability and the
flow-through of tax preferences.
Sole traders and partners in partnerships are
able to access tax-preferred income but they bear liability for
losses of their businesses (unless in limited partnerships); that
is, they do not have limited liability arising from the entity.
Some co-operatives are taxed
differently again from companies under complex arrangements that
can result in different outcomes depending on the timing of
distributions.
The treatment of life insurance investments are
unlikely to be taxed at the policyholder s marginal tax rate.
different tax rates apply to life insurers depending on
the type of institution offering the policy, the nature of the
policy and the investor.(5)
The A
Tax System Redesigned (6)which was a report by a
committee chaired by Mr John Ralph following a review of business
taxation in Australia (Ralph Review) recommended the implementation
of the UER. In the context of the UER the Ralph Review recommended
a broad definition of distribution to enhance the integrity of the
tax system. In its Overview it stated:
A broad definition of distribution is the
simplest and most equitable means of taxing benefits provided by
entities to members. Such a definition adds integrity to the tax
system as it restricts the situations in which value can be shifted
from an entity to a member without being subject to tax. The
recommended definition will apply to the provision of loans, or
goods and services, at less than fair value.(7)
In a
Press Release of 21 September 1999 the Treasurer, the Hon.
Peter Costello, indicated in
Attachment K that the implementation of the entity tax regime
(which was a key recommendation in the Review of Business Taxation)
will provide for a more consistent taxation of business entities
and their members, while being fairer, simpler and having greater
integrity. However, in the light of other pressures on business,
the commencement of this measure was deferred to 1 July 2001.
The need for a change to the UER including a
simplified imputation system was to remove inconsistencies in the
current arrangements which did not contribute to the equity of the
tax system. Further, the non taxation of certain benefits paid by
companies and trusts presented an opportunity for tax avoidance.
This was stated by the Treasurer in Attachment K of his Press
Release of 21 September 1999 as follows.
The recommendation of the Review to adopt a
comprehensive definition of distribution from entities will improve
the fairness of the tax system by ensuring, among other things,
that benefits provided by companies to shareholders and by trusts
to beneficiaries are subject to tax.
The current arrangements are characterised by an
inconsistent treatment of entity distributions, no coherent
approach for dealing with groups of wholly owned entities, and a
lack of integrity in the treatment of inter-entity distributions.
A New Tax System proposed reforms to address these
problems, with implementation from the 2000-01 income year.
In a
Press Release of 11 November 1999, the Treasurer reiterated
that the unified entity tax regime will commence on 1 July
2001.
On 11 October 2000 the Treasurer issued an
exposure draft of the New Business Tax System (Entity Taxation)
Bill 2000 for implementing the UER and the simplified
imputation rules. In
Press Release No 095 of the same date titled Taxing Trusts Like
Companies and Simplified Imputation rules it was emphasised that
the proposed legislation will introduce greater consistency into
the taxation of entities and achieve the objectives outlined in the
ANTS package.
This legislation will implement the Government s
policy, which was announced in A New Tax System, of
introducing greater consistency in the taxation of entities.
There has been extensive consultation in the
development of this legislation. The exposure draft will provide
further opportunity for comment on the operation of the new
arrangements. The exposure draft legislation also covers the
simplified imputation system and franking credits for foreign
dividend withholding tax, and an accompanying explanatory
statement.
The proposed legislation for taxing trusts like
companies achieves the objective of greater consistency in the
taxation of entities while minimising compliance and restructuring
costs. Under this approach, non fixed trusts will be taxed like
companies. Broadly, companies, fixed trusts, limited partnerships
and co-operatives will retain their current tax treatment. This
approach removes the requirement for the introduction of a
collective investment vehicle regime.
On
27 February 2001, the Government withdrew the exposure draft of
the New Business Tax System (Entity Taxation) Bill 2000 conceding
that it was "not workable" and that the Government would look at
alternative approaches.
However, announcing a revised timetable of
Business Tax Reform in a
Press Release of 22 March 2001, the Treasurer stated that the
Government will not be proceeding with draft legislation on entity
taxation. It would therefore appear from the revised timetable that
Government has no intention to resurrect the entity tax regime in
the life of this Parliament. Referring to the simplified imputation
system from 1 July 2002 he stated:
The exposure draft legislation on entity
taxation also contained provisions for simplifying the imputation
system, including imputation credits for foreign dividend
withholding tax. The consultation process has raised several issues
and options which could reduce compliance costs. In giving close
consideration to these, the Government recognises that sufficient
advance notice and certainty of the detail of the final
arrangements is necessary for taxpayers and accordingly will defer
their commencement.
The ANTS package envisaged a full franking
system where all distributions to members of an entity would be
subject to tax at the company rate. In the case of distributions
out of taxable income the entity would have paid tax at the company
tax rate and this tax would be imputed to the members. Where the
distribution is out of profits which has not been subject to tax at
the entity level such distributions would also be taxed at the
entity level at the company tax rate and be called the deferred
company tax . Thus the entity tax paid on taxable income as well as
the deferred company tax paid on distributions out of non-taxable
income would be imputed to members of the entity. Under the
simplified imputation system the entity tax so paid would be
creditable to individual shareholders, beneficiaries, members of
co-operatives or policy holders.
The case for a full franking system was made in
the ANTS package as follows:
There is considerable complexity in the present
system caused by dividends being either franked or unfranked
depending on whether they are paid out of taxable income or not.
Virtually all company profits are taxed. But only taxable income is
subject to company tax (with distributions of these taxed profits
being franked). Other tax-preferred profits are taxed in the hands
of individual shareholders as unfranked dividends when
distributed.
Under a full franking system, taxable income
would, as now for companies, be subject to company tax. In contrast
to current arrangements, however, distributions of other profits,
would be taxed (at the company tax rate) at the entity level,
rather than at the shareholder level. This deferred company tax
would subject distributed tax-preferred income to tax at the entity
level so that all distributions of profit would then be
franked.(8)
The proposal for a deferred company tax on
distributions other than from taxable profits was dropped following
the Ralph Review which recommended against it This was mainly on
the grounds that it would impact adversely on after-tax profits of
Australian companies and consequently adversely affect share prices
and the ability of companies to raise capital.(9)
The imputation system introduced by the three
Bills would continue the complexities that flow from the existence
of franked and unfranked dividends which the ANTS proposal sought
to eliminate.
On 24 May 2002, the Minister for Revenue and Assistant
Treasurer announced in Press Release No. C57/02, the Government s
program for delivering the next stage of business tax reform
measures. In that press release, the Minister confirmed that the
simplified imputation system will commence on 1 July 2002.
This section of the Digest highlights the more
significant provisions which bring about changes to the current
imputation system. To appreciate the changes it is necessary to
know what additional objects the simplified imputation system is to
serve over and above those served by the current imputation
system
The Explanatory Memorandum in paragraph 1.20
states that the new imputation system introduced by the three Bills
have the additional objectives of ensuring that:
-
- the imputation system is not used to give the benefit of income
tax paid by a corporate tax entity to members who do not have a
sufficient economic interest in the entity
-
- the imputation system is not used to prefer some members over
others when passing on the benefits of having paid income tax,
and
-
- the membership of the corporate tax entity is not manipulated
to create either of the above outcomes.
The Explanatory Memorandum sets out succinctly
explanations of the main provisions of the three Bills and the
reader is invited to refer to the EM for greater details.
The simplified imputation system will apply to a
corporate tax entity defined in section 960-115 of the ITAA
1997.
A corporate tax entity is:
-
- a company
-
- a corporate limited partnership in relation to the income
year
-
- a corporate unit trust in relation to the income year, or
-
- a public trading trust in relation to the income year.
The following entities are not corporate tax
entities:
-
- a non-fixed trust
-
- a fixed trust (other than a corporate unit trust or a public
trading trust)
-
- a complying superannuation fund
-
- a complying approved deposit fund, and
-
- a pooled superannuation trust.
It will thus be seen that partnerships (other
than limited partnerships) and trusts (other than corporate unit
trusts and public trading trusts) are not covered by the simplified
imputation system.
Under the current imputation rules a company
that has an early balance date (ie in lieu of the next succeeding
30 June) has a franking year that is aligned to its income year. A
company that has a late balance date (ie in lieu of the preceding
30 June) has a franking year that ends on 30 June. This disparate
treatment of companies that have a late balance date has lead to
unnecessary complexities.
Proposed section 203-40 deals
with the franking period rules for an entity that is not a
private company. It will result in all corporate tax entities
having a franking year that is aligned with its income year and
will remove the complexities that arise to companies with late
balancing dates. The franking periods are generally for six months
and frankable distributions made during such six month periods must
be franked to the same extent.
Proposed section 203-45
provides that the franking period for an entity that is a private
company is the same as the income year.
Proposed Division 205 deals
with franking accounts. It:
-
- creates a franking account for each entity that is, or has
been, a corporate tax entity
-
- identifies when franking credits and debits arise in those
accounts and the amount of those credits and debits
-
- identifies when there is a franking surplus or deficit in the
account, and
-
- creates a liability to pay franking deficit tax if the account
is in deficit at certain times.
These rules essentially replicate the rules
relating to franking credits and debits in the current law. The
most significant departures from the current law are that:
-
- entries are to be recorded on a tax paid basis rather than an
after-tax distributable profits basis, and
-
- the franking account will operate on a rolling balance account
rather than an yearly account with an annual balance transfer.
Under the current system a company credits its
after-tax profit available for distribution to its Franking
Account. Thus if a company derives a taxable profit of $100 and
pays tax of $30, at a rate of 30%, it would credit its Franking
Account by $70. The current system operates on a qualified
dividend account basis or taxed income basis. To
accommodate the changes in company tax rate over time companies at
present maintain a number of different classes of franking accounts
and must carry out a number of complex conversions.
To avoid these complex conversions the new
imputation provisions in proposed Division 205
provide that a franking account will record franking credits on a
tax-paid basis. Thus if a company paid income tax of $30
the corresponding franking credit will be $30. Corporate entities
will not have to convert entries in the franking account to reflect
taxed income.
Under proposed item 5 in the table in
section 205-15 a franking credit will arise if an entity
incurs liability for franking deficit tax. The credit arises by
incurring liability for, rather than payment of, franking deficit
tax. Further, the balance of the account at the end of the year is
brought forward to the beginning of the next income year whether
the account is in surplus or deficit. The effect of the proposed
measure is that the franking account will operate as a rolling
balance account compared to the current imputation rules that
require companies to establish new franking accounts from one
franking year to the next.
Under the current franking rules a company is
required to frank a dividend to the maximum extent possible having
regard to the surplus in its franking account at the time of its
payment. The current system also permits a company to allocate
franking credits representing tax paid on behalf of all members of
an entity to only some of them.
Proposed Division 203introduces
a benchmark rule where a corporate tax entity must frank
all frankable distributions made within a franking period at a
franking percentage set as a benchmark for that period. The rule
for determining the franking percentage is set out in
proposed section 203-35. The franking
percentage of a distribution is calculated as follows:
100 x Franking credit allocated to the frankable
distribution/maximum franking credit for that distribution
Proposed subsection 202-60(2)
ensures that as in the current law an entity cannot allocate a
greater franking credit to a distribution than tax paid by the
corporate tax entity on its underlying profits.
Proposed section 203-15 states
that the object of Subdivision 203-15 is to ensure that one member
of a corporate tax entity is not preferred over another when the
entity franks distributions. The Explanatory Memorandum in
paragraph 2.48 elaborates on this further and states that the
object of the benchmark is to discourage dividend streaming as
follows:
It is a fundamental principle of the imputation
system that corporate tax entities should not be able to direct
franked and unfranked distributions to members in a way that
maximises the benefits to members. Otherwise the cost to revenue
would be higher that originally intended. Instead the benchmark
rule ensures that, over time, the benefit of franking credits is
spread more or less evenly across members in proportion to their
ownership interest in the entity.(10)
The benchmark rule is therefore directed at
dividend streaming and the proposed measures include penalties for
the breach of the benchmark rule as discussed below. The
anti-streaming rules are dealt with in proposed Division
204.
Proposed subsection 203-20(2)
provides that the benchmark rule does not apply to a company if at
all times during the franking period, the company is a listed
public company with a single class of membership interest.
Commissioner s powers to permit a
departure from the benchmark rule
Proposed section 203-55 gives
the Commissioner of Taxation (the Commissioner) the power to permit
a departure from the benchmark rule in extraordinary circumstances
by a determination made either before or after the frankable
distribution is made. The entity must make its application in
writing under proposed subsection 203-55(6). If
the entity or a member of the entity is dissatisfied with the
determination of the Commissioner, the entity or member may under
proposed subsection 203-55(7) object to it in the
manner set out in Part IVC of the Taxation Administration Act
1953.
Penalties for breach of the benchmark
rule
A breach of the benchmark rule will not
invalidate the allocation of franking credits made to the
distribution. However it will result in a penalty to the corporate
tax entity. The penalty is calculated by reference to the
difference between the franking credits actually allocated and the
benchmark percentage. The penalty is under proposed
subsection 203-50(1) either:
-
- over-franking tax, if the franking percentage for the
distribution exceeds the benchmark franking percentage, or
-
- a franking debit (penalty debit), if the franking percentage
for the distribution is less than the benchmark franking
percentage.
The over-franking tax is imposed by measures in
the proposed New Business Tax System (Over-franking Tax) Bill
2002.
A franking debit is equivalent to the extra
franking credit that should have been allocated according to the
benchmark rule. The additional debit cancels the unused credit. In
consequence, if a franking account is in deficit on the last day of
an income year, the entity will be liable to pay franking deficit
tax under the proposed New Business Tax System (Franking Deficit
Tax) Bill 2002.
The benchmark rule sets the framework for
ensuring that over time the benefit of franking credits is spread
more or less evenly across members in proportion to their ownership
interest in the entity. The anti-streaming rules in
proposed Division 204 are intended to prevent the
benchmark rule being undermined. The four specific rules designed
to prevent anti-streaming are as follows.
-
- Proposed Subdivision 204-B deals with linked
distributions and prevents the exploitation of a corporate tax
entity s benchmark percentage by another corporate tax entity, or
that other entity s members, by imposing a franking debit where
there is exploitation. This rule is based on subsections 160AQCB(3)
and (4A) of the ITAA 1936 of the current imputation system
-
- Proposed Subdivision 204-C prevents the
substitution of a tax-exempt bonus share for a franked distribution
by imposing a franking debit on the issue of the share as if it
were a franked distribution. This rule is based on subsection
160AQCB(2) of the ITAA 1936 of the current imputation system
-
- Proposed Subdivision 204-D prevents the
streaming of imputation benefits to one member of a corporate
entity in preference to another by either imposing a franking debit
or denying an imputation benefit where there is streaming. This
rule replicates section 160AQCBA of the ITAA 1936, and
-
- Proposed Subdivision 204-E requires an entity
to notify the Commissioner where there is a significant difference
in its benchmark franking percentage over time, so that the
Commissioner can assess whether there is streaming. This is a new
disclosure rule
The current tax system has 2 different
mechanisms that are designed to prevent the double taxation of
company profits, namely:
-
- an intercorporate dividend rebate for companies and entities
taxed like companies, and
-
- a gross-up and credit approach for all other
entities.
The provisions in proposed Subdivision 207-A of
Division 207 are intended to ensure greater
integrity and consistency by bringing corporate tax entities
receiving franked distributions wholly within the imputation system
instead of relying on the intercorporate dividend rebate in section
46 of the ITAA 1936. The new imputation system will provide a
single rebate/tax offset mechanism, to prevent double taxation of
company profits, which is consistent across all entities. It will
achieve this by using a gross-up and credit approach that
is consistent with that currently used by individuals,
superannuation funds and trustees assessed under Division 6 of the
ITAA 1936.
Proposed section 207-20 sets
out the general rule of grossing-up and tax offset as follows:
(1) If an entity makes a franked distribution to
another entity, the assessable income of the receiving entity, for
the income year in which the distribution is made, includes the
amount of the franking credit on the distribution. This is in
addition to any other amount included in the receiving entity s
assessable income in relation to the distribution under any other
provision of this Act.
(2) The receiving entity is entitled to a tax
offset for the income year in which the distribution is made. The
tax offset is equal to the franking credit on the distribution.
Proposed Subdivision 207-B sets
out the effect of receiving a franked distribution through certain
partnerships and trusts. Under these provisions:
-
- a franked distribution to certain partnerships and trusts is
treated as flowing indirectly to members of the partnership or
trust
-
- each member s share of the franking credit on the distribution
is included in that members assessable income
-
- each member is then given a tax offset equal to that share of
the franking credit, provided the member is not itself a
partnership or trust through which the distribution flows
indirectly, and
-
- where the trustee, rather than a member, is the taxpayer on a
share of the distribution, it is the trustee in that capacity who
is given the tax offset under this Subdivision.
Some recipients of a franked distribution must
satisfy a residency requirement under proposed Subdivision
207-C if their assessable income is to include the
franking credit on the distribution, and they are to be entitled to
a tax offset, under the general rule.
Proposed section 207-75
provides that if an entity mentioned below is resident in Australia
at the time a franked distribution is made it is entitled to the
gross-up and tax offset:
(a) an individual;
(b) a company;
(c) corporate limited partnership;
(d) corporate unit trust; and
(e) a public trading trust.
It is arguable whether the simplified imputation
system proposed to be put in place into the Income Tax
Assessment Act 1997 by the three Bills is anything more than a
tax law improvement project. The imputation system as envisaged
under the Exposure Draft released in October 2000 as an important
component of the unified entity regime (UER) would have been
properly classified as a New Business Tax System reform measure.
However, given the abandonment of the UER by Government in February
2001 any claims that the proposed simplified imputation system is a
true tax reform measure cannot be supported. This is particularly
the case as the Explanatory Memorandum states in paragraph 1.18
that the new imputation system changes the mechanics of the current
system and will provide the same outcome as the current imputation
system
Further, it is clear that the simplified
imputation system as proposed by the three Bills is not
comprehensive. The Explanatory Memorandum states in paragraph 1.4
that further rules are to be included in a later bill and deal with
largely with consequential amendments. It envisages that further
amending legislation will be required to cover rules relating
to:
-
- venture capital franking
-
- life insurance and exemption companies
-
- share capital tainting
-
- holding period and related payment rules,
and
-
- certain transitional and machinery
provisions.
-
- The joint Explanatory Memorandum to the New Business Tax System
(Imputation) Bill 2002; the New Business Tax System (Over-franking
Tax) Bill 2002 and the New Business Tax System (Franking Deficit
Tax) Bill 2002 (the Explanatory Memorandum); paragraph 1.18.
- ibid., p. 3.
- Taxation Laws Amendment (Company Distributions) Act
1987 inserted Part 111AA to the ITAA 1935 dealing with
franking of dividends.
- Tax Reform: not a new tax; a new tax system: The Howard
Government s Plan for a New Tax System (ANTS package);
Circulated by the Hon. Peter Costello MP, Treasurer of the
Commonwealth of Australia (AGPS) August 1998.
- ibid., p. 109.
- Publication: Review of Business
Taxation - A Tax System Redesigned, (Ralph Review).
- ibid., Overview ; para. 289, p. 64.
- ANTS package, p. 116.
- Ralph Review; Overview para.281, p. 62.
- Explanatory Memorandum; para. 2.48, p. 24.
Bernard Pulle
18 June 2002
Bills Digest Service
Information and Research Services
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