185

A.—s

is that I wish to press upon you, if you see your way to it, that legislation should be brought in so as to remove this inequitable tax, as we consider it to be, on the Colonial shareholders. CHANCELLOR OF THE EXCHEQUER {to General Botha) : Have you anything to say upon this topic ? General BOTHA : No, except that I quite agree with that. CHANCELLOR OF THE EXCHEQUER: You associate yourself with what has been said ? General BOTHA : Yes. CHANCELLOR OF THE EXCHEQUER : It does not interest you, Mr. Deakin ? Mr. DEAKIN : Certainly, it interests us because there is a double tax. It interests us quite as much as it does any other part of the Empire, but we have not pressed it further because we understood (I hope I may be undeceived) that your mind was absolutely made up about it, and that there was no chance of our being exempted. That is our position. CHANCELLOR OF THE EXCHEQUER : Of course, as Dr. Jameson knows, he and I have talked about this before. Dr. JAMESON : Sir Joseph Ward is here now, and he may have something to say about it. Sir JOSEPH WARD : I do not know what you have been discussing, but we have had an important question of what we think is dual taxation up very frequently in our country, as to whether there was a possibility of reciprocity where your people come out who are paying income tax legitimately here, and may reside for a time in our country till the arrival of the period for collecting income tax; they invariably complain when asked to pay income tax in our Colony, and we have that reversed of course; people from New Zealand come to the Old Country, and the question is whether it is possible to arrive at the position of saying that we shall not charge an Englishman resident in our country who pays income tax if you say the same to a New Zealand resident who comes to England. If we could arrive at a mutual understanding upon that point it would be very satisfactory to us. I admit it is a very difficult thing to do. CHANCELLOR OF THE EXCHEQUER : It is a difficult thing to do, but that is rather a different point from the one Dr. Jameson has raised. I will take a typical case, the case of the De Beers Company, which has been held liable to income tax here, and I may point out that the tax is a tax, not upon the shareholders, but upon the profits of the Company; of course, indirectly no doubt in the long run it is a tax which falls on the individual shareholders, but the tax is collected here upon the profits made by the Company, and the ground upon which the Company has been held liable is no new ground, it is quite as old as our income tax legislation. It is that the Company has been found in point of fact to be resident here, that is to say, that although the mines which it owns, and the operations for working those mines are carried on in South Africa, what the Courts have held to be the head, the controlling power, the directing power, the brains, and the nerve centre of

25—A. 5.

25 April 1907.

Double Incomb Tax. (Dr. Jameson.)