Income Tax.


property shall be made without the consent, written or other-
wise, of the transferor, such person shall nevertheless be
liable to be taxed on the income derived from the property
transferred in trust, or from property substituted therefore, as
if such transfer had not been made.
 In this section "disposition" includes any trust, grant,
covenant, agreement Or arrangement.

 26. Except where otherwise provided in this Ordinance
any income which by virtue or in consequence of any disposi-
tion mad.,, directly or indirectly, by any person after the 1st
day of January 1960 (other than a disposition made for valu-
able and sufficient consideration), is payable to or applicable
for the benefit of any other person for a period which cannot
exceed six years shall be deemed for all the purposes of this
Ordinance to be income of the person, if living, by whom the
disposition was made, and not, to be the income of any other
person.

 27. (1) With a view to preventing the avoidance or re-
duction of tax it is hereby enacted that where it appears to
the Comptroller that a company has not distributed to its
shareholders as dividends within nine months of the end of
any year or shorter accounting period, a reasonable propor-
tion of its total income from all sources which are assessable
to tax and which could have been distributed without detri-
ment to the company's existing business, the Comptroller may,
at any time within three years of the end of such accounting
period, direct that such proportion shall be deemed to have
been paid as dividend to its members for such period.
 (2) This section shall not apply to any company
unless:-
 (a) not more than five persons together exercise
 control, directly or indirectly, over the com-
 pany's affairs, or
 (b) not more than five persons possess or are
 entitled to acquire the greater part of the
 issued share capital, or
 (e) if the whole of the total income was so deemed
 to be dividend not less than 50% thereof would
 be deemed to be the income of not more than
 five persons:


Dispositions
for short
periods.


Apportionment
of profits of
certain com-
panies among
members.


No. 21.


196V