File 10794.
Ambassador White to
the Secretary of State.
American Embassy,
Paris, December 20,
1907.
No. 161.]Sir: I have the honor to inclose herewith the
copy of a convention having for its object the prevention of frauds, in
respect of
[Page 433]
succession duties
upon the revenues of France and Great Britain, which has just been
concluded between those countries. It is of a somewhat novel character,
not only by reason of its object, but also in that it provides for
direct correspondence in the transmission of information by each
government to the other, between the general direction of registration
in Paris and the board of inland revenue in London, instead of through
the usual diplomatic channels.
The convention though brief, and at first sight not very far reaching in
its effects, has excited a good deal of adverse comment in this country
owing to a feeling that, while it only affects for the present the
succession duty upon personal property left by French citizens in Great
Britain at their death, the information to be supplied in this
connection by the British board of inland revenue will be very useful to
the French minister of finance in the detection of frauds upon the
income tax, should the latter come into existence, as the Government
hopes shortly to persuade Parliament to vote that it shall.
Hitherto it appears to have been not uncommon for those charged with the
settlement of estates left by British subjects and French citizens
partly in France and partly in Great Britain to pay a tax upon such
portions thereof only as happened to be in the country to which the
deceased owed allegiance, the remainder in the other country escaping
the payment of succession duty altogether.
In view of the fact that the succession duties in direct line are more
than twice as large in Great Britain as they are in France, and of the
further fact that an income tax exists already in the former country,
the advantages of the convention would seem for the present to be
greater for England than for France. It has been intimated, however,
that this convention is merely a forerunner of others of a similar
nature between France and the various civilized powers of the world,
with a view to the repression of fraud in fiscal matters which, in that
event, would certainly become more difficult to perpetrate.
I have, etc.,
[Inclosure.—Translation.]
The Journal Officiel publishes to-day the text of the arrangement
concluded at London, “with a view to prevent, as much as possible,
frauds in the cases of succession duties.” This is the document:
The Government of the French Republic and the Government of His
Britannic Majesty, being desirous to prevent, as much as possible,
fraud in the cases of succession duties, have authorized the
undersigned to conclude the following arrangement:
Article 1. The British Government pledges
itself to furnish, for all deceased persons whose domicile is in
France, an extract of the affidavit containing the names, Christian
(or first), domicile, date and place of death of the de cnjus, the
information regarding his successors, and the amount of the
inheritance in personal property. However, the extract shall be
furnished only in cases where the total of this personal reaches a
minimum of £100 sterling.
Art. 2. The French Government pledges
itself to furnish for all deceased persons whose domicile is in the
United Kingdom of Great Britain and Ireland an extract of the
declaration of mutation by death containing the information
enumerated in article 1. However, the extract shall only be
furnished in cases where the total of the personal property declared
reaches a minimum of 2,520 francs.
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Art. 3. The extracts of the affidavits and
of the declarations of mutation shall be certified by the officials
empowered to receive or register those affidavits or
declarations.
However, when one of the two Governments shall deem it necessary,
these extracts shall be indorsed on demand and without costs, with
certifications and legalization of signatures exacted by the
procedure in use in his country.
Art. 4. The extracts and affidavits of the
declarations received or registered during every quarter shall, in
the six weeks following the expiration of that quarter, be forwarded
directly, by the board of inland revenue to the general direction of
registration, and reciprocally.
The correspondence relative to said extracts shall also be exchanged
directly between the two central administrations.
Art. 5. The present arrangement shall be
ratified and the ratifications shall be exchanged at London in the
briefest delay possible.
Art. 6. The first invoice to be sent shall
be the one concerning the quarter of the 1st of January to March,
1908.
Done at London,
in duplicate, the
15th of November, 1907.
[
l. s.] (Signed)
Paul Cambon.
[
l. s.] (Signed)
E. Grey.
