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"While the Queen was not liable to pay any income,

capital gains or inheritance tax in the past, the Governor

has always been subject to all forms of taxation except for

excise duty and salaries tax on his official emoluments ad

Governor of Hong Kong.

"The element that the Governor's salary will be

tax free is clearly set out in his Letter of Appointment.

Such a contractual condition is absent in the case of the

Queen."

The panel has also considered the suggestion that

the Governor should nonetheless pay salaries tax without

any compensation and has conaluded:

package.

"This would mean a reduction in his remuneration

We do not consider this suggestion fair given

that the Governor has accepted his appointment on the terms

offered to him."

Nor does the panel support the suggestion that the

Governor should pay salaries tax but be compensated by a

pay rise to restore his net income:

"This would be an artificial means to achieve the

same remuneration package which would not in effect result

in any material difference."

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