12 Jul 2000
SHIU WING LTD. AND OTHERS v. THE COMMISSIONER OF ESTATE DUTY
- Citation
- SHIU WING LTD. AND OTHERS v. THE COMMISSIONER OF ESTATE DUTY
- Court
- Court of Final Appeal
- Case number
- FACV17/1999
The Court held the Ramsay principle did not justify recharacterising completed, genuine transfers for full consideration into gifts of Hong Kong property; the transactions, viewed realistically, converted Hong Kong assets into offshore specialty debts or foreign proceeds and therefore fell outside s.6(1)(c); quasi-sham and associated-operations arguments failed; accordingly the High Court declaration was restored and the appeal allowed.