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Special issue paper in International Business, Multi-Nationals, and the Nationality of the Company

Changing corporate domicile: The case of the Rhodesian Selection Trust companies

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Abstract

This article explores the transfer of corporate domicile of the Rhodesian Selection Trust group of ‘Free-Standing Companies’ (FSCs) from the UK to Northern Rhodesia. To explore the ‘nationality of the company’ we question how political and economic factors affected strategic decision-making. We contribute further understanding of the impact of international double taxation to the history of FSCs. The article illustrates how the ‘nationality of the firm’ became a contested zone of interaction as British imperial power waned, American capital investment became more dominant, and colonies began to assert themselves in their own ‘national’ interests. We conclude that international taxation was a decisive factor in the relocation of domicile, and was linked to changes in the organizational forms adopted by international business in this period. We use this to contribute to the historiographical debate about the decline of FSCs in the international economy, and the position of business in decolonization.

Disclosure statement

No potential conflict of interest was reported by the authors.

Notes

1 Sidney Pollard, ‘Capital Exports, 1870–1914 Harmful or Beneficial?,’ The Economic History Review 38, no. 4 (1985): 489–514; Michael Edelstein, ‘Foreign Investment and Accumulation, 1860-1914,’ in The Economic History of Britain since 1700, Volume Two: 1860-1939, ed. R. Floud and D. McCloskey (Cambridge: Cambridge University Press, 1994), 173–96; Lance Davis and Robert Huttenback, Mammon and the Pursuit of Empire: The Political Economy of British Imperialism, 1860-1912 (Cambridge: Cambridge University Press, 1986); Lance Davis, ‘The Late Nineteenth-Century British Imperialist: Specification, Quantification and Controlled Conjectures,’ in Gentlemanly Capitalism and British Imperialism, ed. Raymond E. Dumett (London: Longman, 1999), 82–112.

2 Mira Wilkins, ‘The Free-Standing Company, 1870-1914: An Important Type of British Foreign Direct Investment,’ The Economic History Review, New Series, 41, no. 2 (1988), 259–82; Mira Wilkins, ‘The Free-Standing Company Revisited,’ in The Free Standing Company in the World Economy, 1830-1996, ed. Mira Wilkins and Harm Schröter (Oxford: Oxford University Press, 1998), 3–66; For an overview of the development of this concept in international business history see: Tom Houston and John H. Dunning, UK Industry Abroad (London: Financial Times, 1976); Stanley Chapman, ‘British‐Based Investment Groups Before 1914,’ The Economic History Review 38, no. 2 (1985): 230–47; Simon Mollan, ‘The Free-Standing Company: A ‘zombie’ Theory of International Business History?,’ Journal of Management History 22, no. 2 (2018): 156–73.

3 Ranald Michie, The City of London: Continuity and Change since 1850 (London: Macmillan, 1991); Simon Mollan and Ranald Michie, ‘The City of London as an International Commercial and Financial Center since 1900,’ Enterprise and Society 13, no. 3 (January 27, 2012): 538–87,; Kevin Tennent, ‘Owned, Monitored, but Not Always Controlled: Understanding the Success and Failure of Scottish Free-Standing Companies, 1862-1910’ (The London School of Economics and Political Science (LSE), 2009).

4 Rory Miller, ‘British Free-Standing Companies on the West Coast of South America,’ in The Free Standing Company in the World Economy, 1830-1996, ed. Mira Wilkins and Harm Schröter (Oxford: Oxford University Press, 1998), 218–51; Simon Mollan and David K. Kelsey, ‘An Overview of the Business History of the International Mining Industry,’ in Contemporary Issues in Mining, ed. Nigel Finch (Sydney: Palgrave Macmillan, 2012); Stanciu, ‘Free-Standing Companies in the Oil Sector in Romania and Poland Before 1948: Typologies and Competencies’; Tennent, ‘Owned, Monitored, but Not Always Controlled: Understanding the Success and Failure of Scottish Free-Standing Companies, 1862-1910’; Kevin Tennent, ‘Management and the Free-Standing Company: The New Zealand and Australia Land Company c . 1866–1900,’ The Journal of Imperial and Commonwealth History 41, no. 1 (March 2013): 81–97; David Boughey, ‘British Overseas Railways as Free-Standing Companies, 1900–1915,’ Business History 51, no. 3 (May 2009): 484–500; Simon Mollan, ‘Business Failure, Capital Investment and Information: Mining Companies in the Anglo-Egyptian Sudan, 1900–13,’ The Journal of Imperial and Commonwealth History 37, no. 2 (2009): 229–48; Charles Jones, ‘Commercial Banks and Mortgage Companies,’ in Business Imperialism, 1840-1930: An Enquiry Based on British Experience in Latin America, ed. D.C.M. Platt (Oxford: Clarendon Press, 1977), 17–52; Charles Jones, ‘Institutional Forms of British Foreign Direct Investment in South America,’ Business History 39, no. 2 (April 1997): 21–41; Stuart Jones, ‘Origins, Growth and Concentration of Bank Capital in South Africa, 1860–92,’ Business History 36, no. 3 (July 1994): 62–80; Geoffrey Jones, ‘British Overseas Banks as Free-Standing Companies, 1830-1996,’ in The Free Standing Company in the World Economy, 1830-1996, ed. Mira Wilkins and Harm Schröter (Oxford: Oxford University Press, 1998), 344–60; Robert G Greenhill, ‘Investment Group, Free-Standing Company or Multinational? Brazilian Warrant, 1909–52,’ Business History 37, no. 1 (1995): 86–111; Marilyn Gerriets, ‘The Rise and Fall of a Free-Standing Company in Nova Scotia: The General Mining Association,’ Business History 34, no. 3 (1992): 16–48.

5 Wilkins, ‘The Free-Standing Company Revisited’; Mark Casson, ‘Institutional Diversity in Overseas Enterprise: Explaining the Free-Standing Company,’ Business History 36, no. 4 (1994): 95–108; Mark Casson, ‘An Economic Theory of the Free-Standing Company,’ in The Free Standing Company in the World Economy, 1830-1996, ed. Mira Wilkins and Harm Schröter (Oxford: Oxford University Press, 1998), 99–128; Jean-Francois Hennart, ‘Transaction-Cost Theory and the Free-Standing Firm,’ in The Free Standing Company in the World Economy, 1830-1996, ed. Mira Wilkins and Harm Schröter (Oxford: Oxford University Press, 1998), 65–98; T. a. B. Corley, ‘Free-Standing Companies, Their Financing, and Internalisation Theory,’ Business History 36, no. 4 (October 1994): 109–17.

6 Wilkins, ‘The Free-Standing Company Revisited.’

7 Simon Mollan and Kevin Tennent, ‘International Taxation and Corporate Strategy: Evidence from British Overseas Business, circa 1900–1965,’ Business History 57, no. 7 (2015): 1–28.

8 NA T233/2162 'Mr Drake: Item 3 and Item 4', 12 February 1953.

9 LSE Archives, SELECTION TRUST/2009/110 - Selection Secretariat Ltd - Minute Book, 1943-1954, Minutes of 21st Board Meeting Held at the Registered Office on Thursday 18 June 1953; SELECTION TRUST/2009/44 - Board Meeting Minutes, 1950-1956, 217th Board Meeting, 5 February 1953; 222nd Board Meeting, 4 June 1953.

10 NA T233/2161 Minute Sheet ‘S. 468 Income Tax Act 1952: Rhodesian Selection Trust and Associated Companies’, written by Mr. Hunter Johnson, 31 July 1952.

11 Alexander J. Motyl, Imperial Ends: The Decay, Collapse, and Revival of Empires (New York: Columbia University Press, 2013); Michael W Doyle, Empires (Cornell University Press, 1986).

12 Stephen D. Krasner, ‘Rethinking the Sovereign State Model,’ Review of International Studies 27 (2001): 18.

13 Ibid., 17.

14 N. J. White, The business and the politics of decolonization: the British experience in the twentieth century. Economic History Review 53, vol. 3 (2000), pp. 544–564. Cain, P. J. and Hopkins, A. G., British Imperialism, 1688-2000, (Harlow: London, 2001).

15 N. J. White, ‘Government and business divided: Malaya 1945–57’, Journal of Imperial and Commonwealth History, 22 (May 1994). See also Nicholas J. White, ‘Gentlemanly capitalism and empire in the twentieth century: the forgotten case of Malaya, 1914–1965’ in Raymond E, Dumett, Gentlemanly capitalism and British Imperialism: The New Debate on Empire (London: Longman, 1999) pp. 184–188; S. Yacob and N. J. White, The ‘Unfinished Business’ of Malaysia’s Decolonisation: The Origins of the Guthrie ‘Dawn Raid’, Modern Asian Studies, 44, no. 5 (2010), pp. 919–960.

16 L. J. Butler Copper Empire: Mining and the Colonial State in Northern Rhodesia, c.1930–1964 (Basingstoke: Palgrave, 2007), pp. 202–203.

17 The existing historical literature on changes to domcile is limited, but indicates that the context for changes varied considerably. For example one article indicates that Australia refused to allow a wholesale trading firm to relocate domicile from the UK to Australia in the 1970s because of insufficient equity holding in Australia. See Mollan, Simon. 2010. ‘S. Hoffnung and Co: The Case of a Market Intermediary in Australia, 1851–1980.’ Consumption, Markets and Culture 13 (1): 7–30. Dissimilarly, in Malaya in the 1970s, rubber firms were forced to change domicileas a result of government policy despite hostility from the board of directors. See Yacob, Shakila, and Nicholas J. White. 2010. ‘The ‘unfinished Business’ of Malaysia’s Decolonisation: The Origins of the Guthrie ‘Dawn Raid.’’ Modern Asian Studies 44 (5): 919–60. What both articles reveal is that changes of domicile were contingent on political processes that had the capacity to frustrate the intentions of management.

18 Lorraine Eden, Taxing Multinationals: Transfer Pricing and Corporate Income Taxation in North America (Toronto: University of Toronto Press, 1998); Lorraine Eden, ‘Taxes, Transfer Pricing and the Multinational Enterprise,’ in The Handbook of International Business, ed. Alan Rugman and Thomas Brewer (Oxford, 2001), 591–619; Anwar Shah and Joel Slemrod, ‘Do Taxes Matter for Foreign Direct Investment?,’ The World Bank Economic Review 5, no. 3 (1991): 473–91; Assaf Razin and Joel Slemrod, ‘Introduction,’ in Taxation in the Global Economy, ed. Assaf Razin and Joel Slemrod (Chicago: University of Chicago Press, 1990), 1–11; Mollan and Tennent, ‘International Taxation and Corporate Strategy: Evidence from British Overseas Business, circa 1900–1965’; Michael Ashley Havinden and David George Meredith, Colonialism and Development: Britain and Its Tropical Colonies 1850-1960 (London: Routledge, 1993).

19 P. Profeta and S. Scabrosetti, The Political Economy of Taxation: Lessons from Developing Countries (Cheltenham: Edward Elgar, 2010); Martin Daunton, Just Taxes: The Politics of Taxation in Britain, 1914-1979 (Cambridge: Cambridge University Press, 2007); Sol Piccotto, ‘Slicing a Shadow: Business Taxation in an International Framework,’ in Capitalism, Culture and Economic Regulation, ed. L. Hancher and M. Moran (Oxford: Clarendon Press, 1989), 11–47; Roland Paris, ‘The Globalization of Taxation? Electronic Commerce and the Transformation of the State,’ International Studies Quarterly 47, no. 2 (2003): 153–82. Julie H Collins and Douglas A Shackelford, ‘Corporate Domicile and Average Effective Tax Rates: The Cases of Canada, Japan, the United Kingdom, and the United States,’ International Tax and Public Finance 2, no. 1 (1995): 55–83.

20 For a discussion of the origins of double taxation see Rixen, Thomas. The Political Economy of International Tax Governance. Basingstoke: Palgrave Macmillan, 1998.For the impact of double taxation on FSCs see Mollan and Tennent (Citation2015). For the development of taxation in Northern Rhodesia, see Butler, Copper Empire, 196-198.

21 See Mollan and Tennent (Citation2015), passim.

22 Stockwell, Sarah. ‘Trade, Empire, and the Fiscal Context of Imperial Business during Decolonization,’ Economic History Review 57, no. 1 (2004): 142–60; D. K. Fieldhouse. ‘Merchant capital and economic decolonization: The united Africa company 1929-1987.’ (Oxford: OUP, 1994); C. Leys, Underdevelopment in Kenya: The Political Economy of neo-colonialism. (London, Heinemann, 1975); G. Wasserman, Politics of Decolonization : Kenya, Europeans and the Land Issue, 1960-1965 (Cambridge: Cambridge University Press, 1976).

23 Stockwell (Citation2004), p.147.

24 Stockwell, ibid; Mollan and Tennent (Citation2015), p.1065.

25 NA T233/2161 Draft Memo on S. 468 Income Tax Act, 1952, n.d.

26 NA T233/2161 Draft Memo on S. 468 Income Tax Act, 1952, n.d.

27 NA T233/2161 Draft Memo on S. 468 Income Tax Act, 1952, n.d.

28 NA T233/2162 The Migration of Companies (S. 468 of the Income Tax Act, 1952), 20 January 1953.

29 The British Government theoretically retained responsibility for Southern Rhodesia’s ‘Native Department’, however, after the granting of ‘responsible government’ in 1923 the British government did not interfere with any legislation put forward. See Andrew Cohen, ‘The politics and economics of decolonization in Africa: The failed experiment of the Central African Federation (London, I B Tauris 2017) pp. 31–33; and Richard Gray ‘The two nations: Aspects of the development of race relations in the Rhodesias and Nyasaland (Oxford: Oxford University Press, 1960) pp. 12–16.

30 Cranford Pratt, ‘British Colonial Policy in Africa’ in Colin Leys and Cranford Pratt (eds.), A New Deal in Central Africa (Heineman, 1960) p. 42.

31 L. J. Butler Copper Empire: Mining and the Colonial State in Northern Rhodesia, c.1930–1964 (Basingstoke: Palgrave, 2007), p. 202.

32 J. J. B. Somerville, ‘The Central African Federation,’ International Affairs Vol. 39, No. 3 (1963) pp. 387–389.

33 Sir Roy Welensky ‘Welensky’s 4000 days: The life and death of the Federation of Rhodesia and Nyasaland’ (London, Collins: 1964), pp. 22–24.

34 Welensky ‘Welensky’s 4000 days’, pp. 21–44.

35 Murray Steele, ‘Labour and the Central African Federation: Paternalism, Partnership and Black Nationalism, 1951–60’ in Frank et al (ed.) The British Labour Movement and Imperialism (with Foreword by Tony Benn) (Newcastle upon Tyne: Cambridge Scholars, 2010) pp. 132–137, Cohen, ‘The politics and economics of decolonization in Africa’ p. 6.

36 Cohen, ‘The politics and economics of decolonization in Africa’ p. 57.

37 ‘Sir Roy Welensky’ [Obituary] The Daily Telegraph 06/12/1991 p. 19.

38 L. J. Butler Copper Empire: Mining and the Colonial State in Northern Rhodesia, c.1930–1964 (Basingstoke: Palgrave, 2007), p. 210.

39 L. J. Butler, ‘Business and British Decolonisation: Sir Ronald Prain, the Mining Industry and the Central African Federation,’ The Journal of Imperial and Commonwealth History 35, no. 3 (September 2007): 460.

40 NA CO852/868/1 Colonial Economic Development Council (CEDC) Papers and Minutes - Draft Interim Report of the Colonial Development Working Party 1948.

41 NA CAB/134/66 Colonial Office Memo to CCCD ‘Coal for the Copperbelt in Northern Rhodesia’, 17 September 1949. CAB/134/66; Catherine Schenk, Britain and the Sterling Area – From devaluation to convertibility in the 1950’s. London: Routledge, 1994, pp. 8, 35–41; Tomlinson, Jim. Managing the Economy, Managing the People: Narratives of Economic Life in Britain from Beveridge to Brexit. Oxford: Oxford University Press, 2017, pp. 206–213.

42 Barclays Group Archive (BGA) ACC 80/3671 ‘Chairman’s notes on Rhodesian visit February/March 1950’. On a visit to the Rhodesias in 1950, Julian Crossley, Chairman Barclays DCO, noted that the dramatic rise in white immigration to Southern Rhodesia since the war had seen the population double since in 1939. He believed this was a contributory factor to the colonies slow economic progress due to the increased demand on resources. This was demonstrated by the principal municipal power station which regularly had only 24 hours supply of fuel on hand.

43 NA CAB/134/66. Colonial Office Memo to CCCD ‘Coal for the Copperbelt in Northern Rhodesia’, 17 September 1949.

44 NA CAB/134/66 Minutes of CCCD Meeting, 13 January 1950.

45 BGA ACC80/3624 ‘The position of copper in the federal economy’, speech by R. L. Prain, O.B.E at the Bulawayo National Affairs Association, 22 May 1956.

46 Source: The Financial Times, 1 June 1953, 1. Article by Ronald Prain, ‘The Growth of the Copperbelt in Northern Rhodesia’.

47 Butler, ‘Business and British Decolonisation: Sir Ronald Prain, the Mining Industry and the Central African Federation,’ 460.

48 Butler, Copper Empire, passim.

49 NA T233/2162 'Note of Reasons for the Advisory Panel's Recommendation' by R.H. Binder, 23 October 1952.

50 American Heritage Centre (AHC), University of Wyoming, Ronald AHC Prain Papers, 8753-84-09-17 (hereafter AHC AHC Prain Papers), Box 1, File AMCO. Harold K. Hochschild Correspondence, 1950-1951, Statement of Harold Hochschild (hereafter Hochschild), Chairman and President of The American Metal Company, Ltd - Submitted to The Committee on Ways and Means House of Representatives, Friday February 10, 1950.

51 Mollan and Tennent, ‘International Taxation and Corporate Strategy: Evidence from British Overseas Business, circa 1900–1965.’

52 AHC Prain Papers. Box 1. File AMCO. Hochschild Correspondence, 1950-1951, Letter from Hochschild to Ronald Prain, 17 October 1950.

53 AHC Prain Papers. Box 1. File AMCO. Hochschild Correspondence, 1950-1951: Telegram from from Prain to Hochschild, 6 June 1950.

54 AHC Prain Papers. Box 1. File AMCO. Hochschild Correspondence, 1950-1951, Letter from Prain to Hochschild, 20 October 1950.

55 AHC Prain Papers. Box 1. File AMCO. Hochschild Correspondence, 1950-1951: Letter from Harold Hochschild to Ronald Prain, 5 January 1950; Letter from Prain to Hochschild, 11 June 1950.

56 AHC Prain Papers. Box 1. File AMCO. Hochschild Correspondence, 1950-1951: Statement of Hochschild, - Submitted to The Committee on Ways and Means House of Representatives, Friday February 10, 1950.

57 AHC Prain Papers. Box 1. File AMCO. Hochschild Correspondence, 1950-1951: Letter from Hochschild to Prain, 4 January 1951.

58 AHC Prain Papers. Box 1. File AMCO. Hochschild Correspondence, 1950-1951: Letter from Prain to Hochschild, 31 January 1951.

59 AHC Prain Papers. Box 1. File AMCO. Hochschild Correspondence, 1950-1951: Letter from Hochschild to Prain, 17 April 1951.

60 AHC Prain Papers. Box 1. File AMCO. Hochschild Correspondence, 1950-1951: Memorandum by Wm Bringhurst ‘Domicile - Rhodesian Companies’, 25 April 1951.

61 AHC Prain Papers. Box 1. File AMCO. Hochschild Correspondence, 1950-1951: Letter from Prain to Hochschild, 3 May 1951.

62 AHC Prain Papers. Box 1. File AMCO. Hochschild Correspondence, 1950-1951: Memorandum by Wm Bringhurst ‘Domicile - Rhodesian Companies’, 25 April 1951.

63 AHC Prain Papers. Box 1. File AMCO. Hochschild Correspondence, 1950-1951: Ronald Prain to Harold Hochschild, 7 May 1951.

64 Ibid.

65 Ibid.

66 Ibid.

67 AHC Prain Papers. Box 1. File AMCO. Hochschild Correspondence, 1950-1951: Telegram from Hochschild to Prain, 15 June 1951.

68 AHC Prain Papers. Box 1. File AMCO. Hochschild Correspondence, 1950-1951: Prain, Notes on Domicile, 29 September 1951.

69 Ibid.

70 Ibid.

71 Ibid.

72 AHC Prain Papers. Box 1. File AMCO. Hochschild Correspondence, 1950-1951: Letter from Prain to Hochschild, 7 November 1951.

73 AHC Prain Papers. Box 1. File AMCO. Hochschild Correspondence, 1952-54: Letter from Prain to Hochschild, 10 January 1952.

74 NA T233/2161 - Section 468 of Income Tax Act (Migration of Companies): review of policy with special reference to Rhodesian Selection Trust, and Holland, Hannen and Cubitts (1952), ‘Statement from Chairman 8 Jan 1952 with the Directors Report and Accounts for the year ending 30 June 1951.’

75 NA T233/2161 - Section 468 of Income Tax Act (Migration of Companies): review of policy with special reference to Rhodesian Selection Trust, and Holland, Hannen and Cubitts (1952). CAB/129/45 ‘Closer Association in Central Africa: Memorandum by the Secretary of State for the Colonies and Secretary of State for Commonwealth Relations’, 3 May 1951. was

76 NA T233/2161 - Section 468 of Income Tax Act (Migration of Companies): review of policy with special reference to Rhodesian Selection Trust, and Holland, Hannen and Cubitts (1952).

77 NA T233/2161 Advisory Panel Meeting, Rhodesian Selection Trust and Associated Companies (1952).

78 Ibid.

79 BGA ACC38/0209 Julian Crossley, Chairman of Barclays Bank (Dominions, Colonies and Overseas) Diary, 19 January 1951.

80 For an explanation of excess profits tax policies under the Labor government see M. Daunton, Just Taxes: The Politics of Taxation in Britain, 1914-1979, (Cambridge, Cambridge University Press, 2002), pp. 200-203.

81 NA T233/2161 Advisory Panel Meeting, Rhodesian Selection Trust and Associated Companies (1952).

82 NA T233/2161 Memo 'Sir Bernard Gilbert', 30 July 1952; NA T233/2161 Memo to Mr Compton, 28 August 1952.

83 ‘Roan Antelope Copper Mines Ltd,’ The Times [London, England], 4 February 1952, 8.

84 AHC Prain Papers. Box 1. File AMCO.. Hochschild Correspondence, 1952-54: Prain to Hochschild 10 January 1952.

85 AHC Prain Papers. Box 1. File AMCO. Hochschild Correspondence, 1952-54: Bringhurst to Hinves, 21 January 1952.

86 NA T233/2162 'Note of Reasons for the Advisory Panel's Recommendation' by R.H. Binder, 23 October 1952.

87 Ibid.

88 Ibid.

89 NA T233/2162 ‘Mr Drake: Item 3 and Item 4’, 12 February 1953.

90 NA T233/2161 Draft Memo on S. 468 Income Tax Act, 1952, n.d.

91 NA T233/2161 Draft Memo on S. 468 Income Tax Act, 1952, n.d.; NA T233/2161 U.S. Capital Investment in the Commonwealth, 28 August 1952.

92 NA T233/2161 Letter to Mr Lees, 26 November 1952.

93 NA T233/2161 Memo on S. 468 Income Tax Act, 1952.

94 NA T233/2162 Confidential Memo, 23 January 1953.

95 Ibid.

96 NA T233/2162 Memo on S. 468 Income Tax Act, 1952.

97 NA T233/2162 Memo on S. 468 Income Tax Act, 1952 - Appendix 3,

98 NA T233/2162 Mr Compton, Migration of Companies, 4 December 1952.

99 Ibid.

100 NA T233/2162 Mr Leslie Rowan, Migration of Companies from the U.K., 17 December 1952.

101 NA T233/2161 Advisory Panel Meeting, Rhodesian Selection Trust and Associated Companies (1952). Welensky became leader of the ‘unofficials’ within Northern Rhodesia’s Legislative Council in 1945. He was a strong proponent for amalgamation and became the Federation’s Minister for Transport at its creation and eventually Prime Minister in 1956.

102 Andrew Cohen, ‘The politics and economics of decolonization in Africa: The failed experiment of the Central African Federation (London, I B Tauris 2017) p.40

103 NA T233/2161 Roy Welensky to Ronald Prain, 5 May 1952.

104 NA T233/2162 E. Melville, Colonial Office, to H.L. Jenkyns, Treasury, 29 January 1952.

105 NA T233/2162 'Welensky', 29 Janaury, 1952; NA T233/2162 W. Armstrong, Treasury, to E. Melville, Colonial Office, 2 February 1953.

106 NA T233/2162 J.A.R Pimlott to St J. Trend, 5 December 1952; NA T233/2162 St J. Trend to J.A.R, Pimlott, 11 December 1952.

107 NA T233/2162 Oliver Lyttelton, Colonial Office to R.A. Butler, Treasury, 18 December 1952; NA T233/2162 R.A. Butler, Treasury to Oliver Lyttelton, Colonial Office, 23 December 1952.

108 NA T233/2162 ‘Note of reasons for the Advisory Panel's recommendation’, 23 October, 1952; NA T233/2161 S.L. Lees (Treasury) to R.C Nicholas (Inland Revenue), 29 September 1952.

109 NA T233/2162 The Migration of Companies (S. 468 of the Income Tax Act, 1952), 20 January 1953.

110 Ibid.

111 NA T233/2162 The Migration of Companies (S. 468 of the Income Tax Act, 1952), 20 January 1953; NA T233/2162 ‘Draft Letter to R.L. Prain’, n.d.

112 NA T233/2162 Memo, 19 January 1953.

113 NA T233/2162 Mr Trend, ‘Income Tax Act, 1952. Section 468. Relations with the Colonial Office’, 27 January 1953.

114 NA T233/2162 John Boyd Carpenter, Treasury, to Oliver Lyttelton, Colonial Office, 3 March 1953; NA T233/2162 Letter to from Mr Compton to Lord Kennet, 6 March 1953; NA T233/2162 Letter from Lord Kennet to Mr Compton, 6 March 1953.

115 NA T233/2162 Oliver Lyttelton, Colonial Secretary, to RAB Butler, Chancellor of the Exchequer, 17 March 1953.

116 NA T233/2162 The Migration of Companies (S. 468 of the Income Tax Act, 1952), 20 January 1953; David R. Stanford, Overseas Trade Corporations (London: Sweet and Maxwell, 1958); Sarah Stockwell, ‘Trade, Empire, and the Fiscal Context of Imperial Business during Decolonization,’ Economic History Review 57, no. 1 (2004): 142–60.

117 See Michie, Ranald. The London Stock Exchange: A History. Oxford: Oxford University Press, 1999, especially pages 235-286; Mollan, Simon, and Ranald Michie. 2012. ‘The City of London as an International Commercial and Financial Center since 1900.’ Enterprise and Society 13 (3): 538–87.

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