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.