HC Deb 06 December 1933 vol 283 c1496W

asked the Chancellor of the Exchequer whether he is aware that the Controller of Stamps of the Inland Revenue is contending that advances by a parent company to subsidiary companies attract ad valorem duty at 2s. 6d. per cent, under Section 8 of the Finance Act, 1899; whether he is aware that many industrial undertakings now comprise a holding company which raises capital from the public by the issue of shares and debentures, on which stamp duty has been paid, and in turn lends to its subsidiary companies the money which they require; and whether he will take the necessary steps to prevent similar demands being made in the future?


The liability to duty under Section 8 of the Finance Act, 1899, of loan capital of companies depends on the character, and not on the source, of the borrowing. It follows that if the loan is of the kind that comes within the Section liability will attach notwithstanding the fact that the loan may be made to a company by another company which stands to it in the relation of parent or holding company.