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the profits of the company to be ascertained by reference to the proportion of the total profits and income of the com- pany corresponding to the proportion which its premiums from insurance business in the Colony bear to its total premiums, or on any other basis which appears to him to be equitable.

(4) For the purposes of this section "investment income of the Life Insurance Fund'"' means, in the case of a company whose sole business is life insurance, the whole of its income from investments, and, in the case of any other company, such part of its income from investments as appears fairly attributable to its life insurance business.

25. (1) Where a body of persons, whether corporate or unincorporate, carries on a club or similar institution and receives from its members not less than half of its gross receipts on revenue account (including entrance fees and subscriptions), it shall not be deemed to carry on a business; but where less than half of its gross receipts are received from members, the whole of the income from transactions both with members and others (including entrance fees and subscriptions) shall be deemed to be receipts from a business, and the body of persons shall be chargeable in respect of the profits therefrom.

(2) Where a body of persons, whether corporate or unincorporate, carries on a trade association in such circum- stances that more than half its receipts by way of entrance fees and subscriptions are from persons who claim or would be entitled to claim that such sums were allowable deductions for the purposes of section 17, such body of persons shall be deemed to carry on a business, and the whole of its income from transactions both with members and others (including entrance fees and subscriptions) shall be deemed to be receipts from business, and the body of persons shall be chargeable in respect of the profits therefrom.

(3) In this section, "members", in relation to a body of persons, means those persons who are entitled to vote at a general meeting of the body at which effective control is exercised over its affairs.

Clubs, trade associations,

etc.

Property Tax from Profit Tax

26. There shall be deducted from any profits tax payable Deduction of under this Chapter in respect of any trade, profession or business any Property Tax payable under Chapter II of this Ordinance, in respect of any land and/or buildings, by such trade, profession or business.

Certain

27. For the purposes of assessment the dividends of a corporation, which is subject to tax under this Chapter, dividends shall not be included in the profits of any other person for the purposes of taxation under this Chapter.

excluded from assess- ment of profits

tax from dividends of companies

28. (1) Every company which is registered in the Deduction of Colony shall be entitled to deduct from the amount of any dividend paid to any shareholder tax at the rate paid or payable by the company (as reduced by any relief granted under sections 45 and 46) on the income out of which such dividend is paid, provided that where tax is not paid or pay- able by the company on the whole income out of which the dividend is paid the deduction shall be restricted to that portion of the dividend which is paid out of income on which

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