362 SECRETARIAL PRACTICE 
of three years from the date when the duty becomes charge- 
able—that is to say, the first issue of the security, or, in 
the case of a security not issued in the United Kingdom, 
the first transfer, or negotiation in the United Kingdom— 
and the date is conspicuously stated on the face of the 
security. The reduced duty, which applies to all bearer 
securities not being colonial government securities, is for 
every £10, or fractional part, 6d., if the security will expire 
within a year, and 1s. if the security will expire after a year 
and within three years; and it 41s provided that if the security 
is not paid off within the stated period, and there is any 
subsequent dealing, the full rate of duty shall become 
payable, subject to an allowance of the duty already paid. 
The duty chargeable in respect of a substituted security 
Joes not apply where the reduced rate of duty is paid under 
“his section. 
Loans repay- The duty is charged on the amount secured, and accord- 
ible 5 a ingly, if a debenture is issued upon a loan of a sum repayable 
"unconditionally with a premium thereon, the aggregate 
amount of the loan and the premium is the amount secured 
upon which the duty is payable. This was decided in the 
case of Rowell v. The Commissioners of Inland Revenue [(1897), 
2 Q.B. 194], but is was subsequently held that if the terms of 
the debenture are such that the premium mentioned therein is 
only payable if it is paid off upon a notice, so that the payment 
of the premium merely depends upon the will and pleasure of 
the company, who are under no obligation to give the notice, 
the premium is not to be taken into account in computing the 
duty [Knights Deep Limited v. Inland Revenue (1900), 1 Q.B. 
217], and this principle is considered to be equally applicable 
to a premium which will become payable only in the case of 
the voluntary winding up of the company issuing the security. 
Questions have arisen as to the extent of the charge of 
duty on a debenture, and reference may be made to the case 
of The British India Steam Navigation Co. v. The Com- 
missioners of Inland Revenue, 7 Q.B.D. 165, decided in 
1881, which related to an instrument not under seal issued 
by an English company, with coupons for interest attached, 
and purporting on the face of it to be a debenture, and to 
the decision of the House of Lords in 1908 in the case of 
Speyer Bros. v. The Commissioners of Inland Revenue (1907), 
1 K.B. 246, which related to a Treasury note issued by a 
foreign government with coupons for interest attached, 
although giving no security to the holder beyond the promise 
to pay the face amount of the note, in both of which cases it 
was held that the charge of duty applied. It was held in