58.Estate and Succession Taxes: These taxes have not so far been levied. One of the hurdles to be crossed before they can be levied is the determination of the manner of distribution of the net proceeds among provinces. Until the taxes are actually levied and collected for some time, no data about their incidence will be available. Hence, the levy will have to start with some a priori basis of apportionment among provinces. We accordingly recommend that until the Finance Commission is in a position to evolve a better method on the basis of data available to it, the net proceeds should be distributed among the provinces as follows:

The net proceeds attributable to real property—On the basis of the location of the property.

Of the balance—

75 per cent. on the basis of the residence of the deceased;

25 per cent. on the basis of the population of the province:

The administration and distribution of these taxes would, in the ordinary course, fall on the Central Board of Revenue, but it would be necessary to empower an appropriate authority to adjudicate in the case of disputes between provinces as to the residence of individuals.