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deceased shareholder held on a register outside Hong-Kong
are for purposes of Hong-Kong death duties deemed to be
part of the estate situate in Hong-Kong, if, but only if,
he has died domiciled in Hong-Kong.
The
It seems possible that there may be some
misapprehension as to the effect of this provision.
Hong-Kong Government no doubt realise that the establish-
ment of London registers involves some gain of estate
duty to Great Britain but may think that the gain would
not extend to shares held on those registers by persons
who died domiciled in Hong-Kong.
This is not the case,
as, despite the provision of the Hong-Kong law mentioned
in the preceding paragraph, such shares, like any other shares held on the London registers, would constitute
British assets liable to British Estate Duty.
It is not
clear
G