STAMP DUTIES

367

held that the exemption only applied to bills drawn for
the sole purpose of remitting and placing to its proper
account money which is already public money and was not
therefore applicable to a transfer order on the Bank of
England issued by the bank to a customer desiring to pay
taxes by this means.

The principal exemption in which secretaries of companies
are interested is that in favour of coupons. This exemption
was originally limited to coupons attached to and issued with
any security. It was extended in 1889 to coupons issued
with an agreement or memorandum for the renewal or exten-
sion of time for payment of a security, and in 1894, to any
coupon being one of a set of coupons whether issued with
the security or subsequently issued in a sheet. The last
extension followed a decision [Rothschild v. Inland Revenue
1894), 2 Q.B. 142] that a coupon issued upon the exhaustion
of the coupons attached to a perpetual security was not
exempt.

The duty payable upon a protest by a notary public de- Protest by
pends upon the amount for which the bill or note was given. Notary.
[f the amount does not exceed £100, so that the duty on the
bill or note does not exceed 1s., the duty on the protest is
the same as that paid upon the bill or note. In any other
case, the duty on the protest is 1s. This duty may be denoted
by an adhesive stamp.

For the purpose of stamp duty, a policy of insurance is
defined by s. 91 of the Act of 1891 as including ‘every writing
whereby any contract of insurance is made or agreed to be
made or is evidenced,” and the charges of duty vary according
as the policy is for:—

Sea Insurance;
Life Insurance; or any other form of insurance.

A contract chargeable as a policy of sea insurance applies
to the insurance of a ship, or the machinery, tackle, or furniture
of a ship or any goods on board or of the freight or any other
interest which may lawfully be insured in or relating to any
ship, and may cover in the case of goods not only a sea
risk but also other risks incidental to the transit of the goods
from the commencement of the transit to the ultimate destina-
tion covered by the insurance. Such a contract is not valid
unless it is expressed in a policy.

In considering the stamp duty payable on policies of sea
insurance it is important to bear in mind that it is provided
in s. 91 of the Marine Insurance Act, 1906, by which Act the
~rdinary law relating to marine insurance is codified that

Exemption in
favour of
Coupons.

Policies of
Insurance.

Policies of
Sea
Insurance.