CO129-482 - Public Offices - 1923 — Page 446

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The British American Tobacco Co., Ltd.,

wrote to us * 63116/22 to complain about the fees payable by the Company under the Hong Kong China Companies Ordinance, There points were that :-

(1) The B.A.T. Co.Ltd., owed practically all the sheres in the B.A.(China)(Co, Ltd., and that the latter Company owned nearly all the shares in certain subsidiary Companies, all of which were China Compan

Kong Ordinance No.31 of 1915, the re Companies in lieu of stamp duties, probate duty and estate duty had to pay an annual fee at the rate of 4 cents for every 100 dollars of the paid up capital of the Company to the Colonial Treasurer, Hong Kong.

ies, and by Section 7, subsection (4) of Hong

(2) The B.A.T. Co. (China) Ltd. was incorporated in 1919 and the capital of this Company was partly based on the actual assete plus the good will of the subsidiary Companies. Therefore, the whole amount of the issued capital of those Companies ar at February 1919 was duplicated in the capital of B.A.T.Co.(China) Ltd.

(3) After pointing out that in a full year the B.A.T. Co. (China) Ltd and subsidiary Companies paid substantially more than 50% of the total tax payable ry China Companies the Directore eubmitted that it was inequitable that a Company should be taxed twice in respect of the same assets and that even if there

was not this duplication of

taxation the total

amount