QQVENUGU MUVOC MUNU NUMU.

THU 27 MAY 92 08:19

PG.11

CONFIDENTIAL

Changes in the Queen's tax position

9.

As far as the legal position is-concerned, the Queen is not legally liable to pay any income tax, capital gains tax or inheritance tax because the relevant enactments do not apply to the Crown. The Governor's case is different since only his official emoluments are exempted from payment of salaries tax and he is liable to other forms of taxation.

10.

In response to the Queen's proposal that she would pay income, capital gains and inheritance tax on a voluntary basis, three Royal trustees were appointed to review the Queen's tax position. They have published a report which contains a Memorandum of Understanding on Royal Taxation (Annex C). The Memorandum sets out in detail the tax arrangements which began to take effect

from April 1993.

11.

The main features of the changes which might be

of some relevance to the current exercise are as follows

(a)

Income tax

Tax will be paid on all private sources of income such as investment income and

farming profits.

Tax will be paid on the Queen's Privy Purse

Income to the extent that the income is

used for personal purposes.

CONFIDENTIAL

Share This Page