§ MR. RADFORD (Islington, E.)I beg to ask Mr. Chancellor of the Exchequer whether he is aware that in recent cases under The Finance Act, 1894, not covered by the case of In re Campbell or any other legal decision, the Commissioners of Inland Revenue have demanded Settlement Estate Duty on the capital required to produce in perpetuity annuities given by testators in general terms without any special fund being appropriated to provide the same, and that the result of such a demand is to impose an obligation to pay (in addition to Legacy Duty) Settlement Estate Duty not on the capital value of the annuity but on a larger sum, with the 1302 consequence that the duty in some cases amounts to 14 and 20 per cent, on the capital value of such annuities; and whether he will give directions to the Commissioners of Inland Revenue to prevent such claims being made in the future in the case of simple annuities.
§ THE FINANCIAL SECRETARY TO THE TREASURY (Mr. MCKENNA, Monmouthshire, N.): Where Settlement Estate Duty is chargeable in respect of settled property as denned by the Finance Act, 1894, it is chargeable by the Statute upon the principal value of the property settled and not upon the principal value of the terminable interests whether annuities or life interests. The question whether the property is settled has to be determined with reference to the circumstances of each case. The gift of a simple annuity, neither charged on real or leasehold property, nor directed to be paid out of income, is not held to constitute a settlement giving rise to Settlement Estate Duty. If my hon. friend will supply me with particulars of any case or cases of hardship which he has in view, I shall be happy to investigate them.