THE initiative taken by the Minister for Finance, Mr Quinn, in publishing the heads of the 1996 Finance Bill so soon after the Budget statement will be welcomed by tax practitioners and industry representative groups. He hopes that, since this will allow more time for detailed consideration of the proposals by interested parties, there will be a more informed debate on the provisions before the detailed text is published.

However, his hopes may be disappointed this year because insufficient detail has been provided to generate constructive consideration or informed debate.

For example: a 30 par cent rate of corporation tax was announced in the Budget, to apply to the first £50,000 of company/group income. What tax practitioners and business people will be really interested in is how the £50,000 is to be allocated in a group context. They will wish to ensure that there is no leakage or wasting of the low rate due to the profitability profile of companies within a group.

The published outline contains no new information on this proposal over and above that contained in the Budget, so there can be no debate on this point.

Another example: certain IFSC companies are being allowed to hold units in IFSC managed collective funds without affecting their favourable tax status. Tax practitioners and fund industry representatives need to know exactly who the certain IFSC companies are in order to enter into any meaningful dialogue.

Several similar examples could be provided.

The hope must be that in future a little more time could be taken in drafting the outline proposals so they could contain more precise wording which would generate informed debate.

The proposals published last week are in two sections. The first confirms measures announced in the Budget and gives little or no additional detail. The record brings forward some new measures. Many are highly technical and of limited application.

Among the more interesting are the following:

. Stamp Duty: Heretofore stamp duty has been a tax on written instruments. The introduction of a paperless settlement system - CREST - for the transfer of shares with a Stock Exchange quotation represents a threat to the stamp duty yield of 1 per cent on the registration of such share transfers.

Discussions are being proposed with interested parties and these may lead to the introduction of a stamp duty on electronic transfers - a very radical departure from previous practice. The fine print of the actual Bill will be awaited with much interest.

. International Financial Services Centre: Since the establishment of the IFSC there has been a welcome willingness by various Government departments and regulatory agencies to make it work. Every Finance Act in recent years has contained positive and, in many cases, imaginative measures. This year's Bill is no exception.

While I have commented earlier about the vagueness of the proposal to allow certain IFSC companies to hold units in IFSC managed collective funds, the initiative is clearly positive and will facilitate the further development of the centre. A separate provision will allow IFSC funds undertakings to pay interest without withholding tax to non residents.

A further measure will remove technical barriers to the establishment of securitisation vehicles in the IFSC. Securitisation projects are emerging as an important new segment of IFSC business and the move is clearly very positive although, again, the details are quite unspecific.

Some foreign owned companies, many IFSC based, have non Irish functional currencies and prepare their accounts in foreign currencies. However, tax liabilities must be paid in Irish pounds, some six months after, year end. If they do not buy Irish pounds? forward to discharge the liability, they will almost certainly show an exchange gain or loss on their tax payments.

Previously this has been outside the scope: of taxation. However, if they hedge the exposure, they potentially have a capital gains tax gain or loss - at a 40 per cent rate. This is clearly anomalous in the case of a 10 per cent trading company. The Bill is to contain proposals to remove the anomaly, but how this is to be done is not yet specified.

. Greyhounds: Genuinely new tax incentives have been extremely scarce recently. This makes provisions affecting greyhounds of particular interest. Off course duty is being, abolished on bets placed at greyhound tracks' in respect of events taking place at other locations.

Even better, there will be a new tax incentive for greyhound owners. There is an existing total exemption from tax in respect of stallion stud fees. This is to be extended to greyhound stud fees.

. Industrial Buildings: Of course there are also some disappointing features in the proposals. The industrial buildings allowance for capital expenditure is being retained at the rate of 4 per cent annually. This compares very unfavourably with the 15 per cent annual allowance available for capital expenditure on plant and machinery.

. Participation Exemption: Even more disappointing is the absence of any provision for a participation exemption - enabling the income and/or capital gains of Irish owned foreign subsidiaries or branches to be repatriated free of Irish tax. Of EU member states, Ireland and Greece are now the only two which do not accord some form of participation exemption.a