No. 21. Income Tax. 1967. pect of any territory outside the Colony with which there is a double taxation agreement between that territory and the Colony ex- cept to the extent that the tax payable out- side the Colony remains unrelieved. 11. (1) Where the amount of a loss incurred in the year Allowance for preceding any year of assessment in any trade, business, trade loss. profession or vocation carried on by any person either solely or in partnership is such that it cannot be wholly set-off against his income from other sources for the same year, the amount of such loss shall to the extent to which it is not allowed against his income from other sources for the same year be carried forward and shall, subject as is hereinafter provided, be set-off against what would otherwise have been his chargeable income for all following years in succession, provided that the amount of any such loss allowed to be set- off in computing the chargeable income of any year shall not be set-off in computing the chargeable income of any other year and provided also that in no ease shall such set-off be allowed to an extent which would reduce the tax payable for any year of assessment to less than one-half of the amount which would have been payable had the set-off not been allowed and provided also that no loss should be relieved either against other income for the same year or carried for- ward under this section unless it is shown that the trade was being carried on for the year of loss on a commercial basis and with a view to the realisation of profits in the trade. (2) No loss incurred during a Tax Holiday Period shall Tax holiday be set-off against the income from other sources for the same losses. year, but the net loss incurred during the whole of the Tax Holiday Period shall he available to be carried forward to the post-holiday period for set-off under the provisions of the foregoing subsection. 12. Notwithstanding anything to the contrary contained Insurance and in this Ordinance it is hereby provided that- Shipping Com- (a) in the ease of an insurance company (other l ' than a life insurance company) where the gains or profits accrue in part outside the Colony, the gains or profits on which tax is payable shall be ascertained by taking the gross pre- miums and interest and other income received or receivable in the Colony (less any premiums