the suggestions is unprecedented as it is substantially
the "actice of a number of foreign income tax adminis-
trations and of the Union of South Africa. They have
referred in this connection to a publication on the taxa-
tion of foreign and national enterprise of which I will
try and obtain a copy to send to you, as they say it
contains useful information. Moreover, in the course
of the discussion it seemd probable that there was no
practical difference between "profits made in the Colony"
and "profits arising in the Colony" which is a phrase
recommended in the report on the model income tax for
Colonies. That report proposed to confine Colonial
income taxes to profits arising in the Colony and profits
brought into the Colony in order to avoid the difficult
question of residence and control. Since Hong Kong 18
deliberately leaving out profits brought into the Colony
they will as to the rest of it be following the proposals
of the report and precisely for the reasons suggested by
it, that is to avoid difficult questions as to residence
and control.
The
95