CO129-482 - Public Offices - 1923 — Page 442

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imposed by the above section is too high, as they say "greatly

in excess of any moneys which would be received by the Colony by way of stamp duties on transfers, estate duty or probate duty if the company were a Hongkong company".

is not supported by any figures or calculations.

This statement

If it were

I should be prepared to consider a reduction of the fee.

5.

I should also be prepared to consider the making of some arrangement to avoid the duplication of taxation com- plained of by this company. Perhaps the simplest way would be to charge the fee only on the capital of the British American Tobacco Company (China) Limited.

6. In the penultimate paragraph of their letter the company seem to suggest that the total amount of the licence fee collected from China companies should only be enough

to pay the cost of the registry at Shanghai. This is clearly wrong.

The

fee was intended to compensate the Colony for the lose of estate duty and transfer duty. In this connection it is important to remember that shares in China companies, 28 I understand the position, pay no estate duty to any British authority except where they form part of the estate of a deceased British subject.

7. In the last paragraph of their letter the company suggest that no fee should be levied on any capital in excess of $5,000,000. I cannot accept this proposal. It might have been sound if the fee had been imposed to pay the expenseB of a registry, but the proposal is quite inappropriate to the case of a fee which has been imposed in lieu of estate and transfer duty.

8.

As the whole question of this licence fee is now under consideration, and as the tax has now been in operation for seven years, I may add that I should be prepared to reconsider the amount of the contribution to the Shanghai registry if adequate reasons can be shown for increasing it.

(Sgd.)

R.E. Stubbs.