File 4011/1923 Pt 2 'PERSIAN GULF: NEGOTIATIONS 1928 HENJAM' [357v] (719/1934)
The record is made up of 1 volume (962 folios). It was created in 6 Jul 1926-25 Jan 1934. It was written in English and French. The original is part of the British Library: India Office The department of the British Government to which the Government of India reported between 1858 and 1947. The successor to the Court of Directors. Records and Private Papers Documents collected in a private capacity. .
Transcription
This transcription is created automatically. It may contain errors.
2
directement entre ie Gouvernement Imperial et le £ Anglo-Per si an ” et non d
avec mon Gouvernement, qni n’a jamais conclu un accord a ce suiet av
n’importe quel autre Gouvernement etranger. Je yous envoie ci-inclus un aitT
memoire explicatif. C’est vrai que la double imposition a ete discutee a Geneve
mais aucune decision n’a ete prise et on est encore bien loin d’un accord general'
De notre cote, nous desirons, a part la question de Bahrein et celle des visite
des bateaux de guerre dans vos ports, certaines modifications dans le proiet du
protocole sur Henjam dans le but d’ecarter toute possibilite de malentendu et de
friction locale. En outre, nous voudrions voir enlevees les restrictions onereuses
sur Femploi du sans-fil.
Einalement, la question des reclamations, surtout celles du Persian Railway
Syndicate. II est essential, a 1’avis de mon Gouvernement, d’envisager dans l’e
traite une solution. Je vous prie de bien vouloir penser serieusement a cette
question et me faire savoir ce que vous proposez.
Voulez-vous avoir I’obligeance d’envoyer votre reponse par 1’intermediate
de Parr, qui a ete charge de vous faire parvenir cette lettre.
Je vous prie, &c.
E. H. CLIVE.
Enclosure 2 in No. 1 .
Note regarding Double Taxation (enclosed in Sir R. Clive's Letter of January h
to the Minister of Court).
1. UNDER the Income Tax Law of the United Kingdom a person resident
in the United Kingdom is liable to income tax on the whole of his income, whether
derived from sources in the United Kingdom or from sources abroad.
Consequently, a person (whether a natural person or a corporation), resident in
the United Kingdom, who carries on business partly in the United Kingdom and
partly abroad, is liable to United Kingdom income tax on the whole of his profits.
If the part of the profits earned abroad is liable to taxation abroad, the tax so
paid abroad is allowed to be debited as a trading expense in arriving at the profits
assessable to United Kingdom income tax, but the tax so paid abroad is not
allowed to be set off against the tax payable in the United Kingdom.
2. In these circumstances, the part of the profits earned abroad will be
liable to double taxation, and in a very large number of cases such double taxation
actually exists. Various suggestions have from time to time been made for
avoiding this double taxation, and among them is the suggestion that the country
in which the trader resides should allow from its own charge of duty a deduction
equal to the amount of the tax charged abroad on the profits earned there.
3. This solution of the double taxation problem is not likely to commend
itself to the United Kingdom Government. In fact, such arrangements as have
been made or are under discussion between the United Kingdom Government and
foreign Governments for the avoidance of double income-taxation (e.g., in relation
to profits arising from shipping businesses and from trade carried on through
agents), proceed on the basis that the profits shall be taxed only by the country in
which the trader resides, the country in which the profits arise giving up its claim
to tax.
4. There is in existence between the United Kingdom and other parts of the
British Empire a general scheme for the avoidance or relief of double income-
taxation, based on a different principle. But in this case special considerations
prevail, in view of the close relations between the constituent members of the
Empire, and it is not in contemplation to extend that scheme to foreign countries.
And, clearly, it would not be possible to apply this principle to any one foreign
country in particular (e.g., Persia) without applying it to all. It is, therefore,
impossible to treat the proposals of the Persian Government otherwise than as
part of a general problem, the solution to which is not yet in sight.
January 14, 1931.
About this item
- Content
This volume relates to British policy regarding the Gulf island of Henjam [Jazīreh-ye Hengām], occupied in part, on and off, by the British since the late nineteenth century.
Interdepartmental correspondence refers to the establishment of a British telegraph station on the island in 1868, following a concession from the Persian Government, which was abandoned in 1881 but re-established in 1904. The correspondence also acknowledges that further developments since then, including the establishment of a wireless station and a naval coal depot, represent an encroachment by the British Government.
The main topic of discussion is the extent of the British claim (or lack thereof) to Henjam, and the continued use of the island as a fuelling and recreational station for British naval forces in the Gulf.
Related matters of discussion include the following:
- The possibility of consolidating the British position at Henjam by offering to surrender Basidu to Persia
- The British response to Persian forces expelling the Arab Shaikh of Henjam from the island in May 1928, in retaliation for the Shaikh attacking and looting the island's customs office the previous year
- The drafting of a protocol (as part of wider Anglo-Persian negotiations, which are referred to throughout) in 1929 between the British and Persian governments, setting out the terms for the British Government's surrender of its claims to Basidu and Henjam, in return for continued access to facilities at Henjam, possibly in the form of a lease
- The consideration of alternative locations for a naval station, in the event of it being necessary for the British to relinquish their hold on Henjam
- Whether the British should be prepared to offer the Persian Navy docking and refitting facilities at Bombay or Karachi, on 'favourable terms', in return for their continued use of the facilities at Henjam
- A request from the Persian Government in September 1932 for the immediate withdrawal of the British naval establishment, following the Persian Government's decision to use Henjam as the location for six recently purchased naval vessels
- The possibility of the British naval depot at Henjam being relocated either to Basidu or Bahrein [Bahrain].
The volume features the following principal correspondents: the British Minister in Tehran, the Secretary of State for Foreign Affairs, and officials of the Admiralty, the Foreign Office, and the India Office The department of the British Government to which the Government of India reported between 1858 and 1947. The successor to the Court of Directors. . Other notable correspondents include the following: the Political Resident A senior ranking political representative (equivalent to a Consul General) from the diplomatic corps of the Government of India or one of its subordinate provincial governments, in charge of a Political Residency. in the Persian Gulf The historical term used to describe the body of water between the Arabian Peninsula and Iran. ; the Viceroy of India; the Senior Naval Officer in the Persian Gulf The historical term used to describe the body of water between the Arabian Peninsula and Iran. ; the Foreign Secretary to the Government of India; the Persian Minister for Foreign Affairs; officials of the British Legation at Tehran and the Government of India's Foreign and Political Department.
Also included in the volume are the following: a précis of printed correspondence relating to British positions at Basidu and Henjam, covering the period 1821-1905 (ff 898-941); an India Office The department of the British Government to which the Government of India reported between 1858 and 1947. The successor to the Court of Directors. memorandum entitled 'Henjam. Position and Rights of His Majesty's Government in the Island of Henjam', dated 26 September 1928 (ff 723-726); copies of the minutes of two meetings of the Committee of Imperial Defence's Standing Official Sub-Committee for Questions Concerning the Middle East, dated 17 December 1931 (ff 249-262) and 10 October 1933 (ff 12-28); a copy of a memorandum by the Admiralty and the Foreign Office on the British naval depot at Henjam, dated 23 February 1932 (ff 197-208).
The French language material consists of correspondence from Belgian customs officials writing on behalf of the Persian Government, as well as articles from the aforementioned draft protocol, and correspondence between the Persian Minister for Foreign Affairs and the British Minister at Tehran. English translations are included in some but not all cases.
The volume includes two dividers which give the subject number, the year the subject file was opened, the subject heading, and a list of correspondence references by year. These are placed at the back of the correspondence (ff 4-5).
- Extent and format
- 1 volume (962 folios)
- Arrangement
The papers are arranged in approximate chronological order from the rear to the front of the volume.
The subject 4011 ( Persian Gulf The historical term used to describe the body of water between the Arabian Peninsula and Iran. Negotiations) consists of two volumes, IOR/L/PS/10/1094-1095. The volumes are divided into two parts, with each part comprising one volume.
- Physical characteristics
Foliation: the foliation sequence (used for referencing) commences at the inside front cover with 1, and terminates at the inside back cover with 964; these numbers are written in pencil, are circled, and are located in the top right corner of the recto The front of a sheet of paper or leaf, often abbreviated to 'r'. side of each folio.
- Written in
- English and French in Latin script View the complete information for this record
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- Reference
- IOR/L/PS/10/1095
- Title
- File 4011/1923 Pt 2 'PERSIAN GULF: NEGOTIATIONS 1928 HENJAM'
- Pages
- front, back, spine, edge, head, tail, front-i, 2r:7v, 10r:46r, 47v, 49r:60r, 61r:68v, 71r:104v, 106r:117v, 119r:192v, 194r:241v, 243r:283v, 285r:288v, 290r:368v, 370r:401v, 405r:406v, 408r:422v, 425r:471v, 475r:487v, 489r:490v, 492r:516v, 521r:532v, 534r:565v, 572r:610v, 612r:612v, 615r:627r, 629r:654v, 660r:668v, 678r:692v, 694r:792v, 794r:802v, 805r:812r, 813r:854v, 855ar:855av, 855r:859v, 862r:870v, 873r:877v, 880r:911r, 912r:921r, 922r:922v, 924v:932r, 933v:939v, 940v:963v, back-i
- Author
- East India Company, the Board of Control, the India Office, or other British Government Department
- Usage terms
- Open Government Licence