30 Sept 2022
JOHN WILEY & SONS UK2 LLP AND ANOTHER v. THE COLLECTOR OF STAMP REVENUE
- Citation
- [2022] HKDC 1078
- Court
- District Court
- Case number
- DCSA2/2021
Leave to appeal was refused because the proposed grounds had no reasonable prospect of success: the trial judge had considered context and purpose and correctly applied the ordinary and natural meaning of 'issued share capital'; the Collector's alternative contexts and anti‑avoidance purpose did not justify overturning the interpretation; the novelty of the point alone did not meet the interests of justice threshold for leave.