22 Oct 2018
WONG YAU CHUNG 對 THE COLLECTOR OF STAMP REVENUE
- Citation
- [2018] HKDC 1265
- Court
- District Court
- Case number
- DCSA99/2016
The court found on the facts that the two sales formed an integral, coordinated series of transactions (same vendor, same floor, same prices and deposits, simultaneous agreements and conveyances, clause 45 conditioning completion), therefore s29(1) did not protect the individual HK$100 certification and the aggregate consideration must be used; accordingly the ad valorem rate (2.25%) under Schedule 1 applied and the Commissioner’s assessments were correct and within the six-year limitation, so the appeals were dismissed.