File 10794.

Ambassador White to the Secretary of State.

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.,

Henry White.
[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.

[Page 434]

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.


[l. s.] (Signed)
Paul Cambon.

[l. s.] (Signed)
E. Grey.