15 Jul 2022
JOHN WILEY & SONS UK2 LLP AND ANOTHER v. THE COLLECTOR OF STAMP REVENUE
- Citation
- [2022] HKDC 716
- Court
- District Court
- Case number
- DCSA2/2021
The court held that "issued share capital" in section 45 must be construed by its ordinary and natural meaning in light of the legislative purpose: capital divided into quantifiable portions (shares) as legally recognized in the jurisdiction of incorporation. LLPs can have such issued share capital where their capital is so divided and issued under their governing agreement and applicable law. The JWSLLPs each had issued share capital of GBP100 divided into GBP99 and GBP1 which were issued to members; accordingly the Appellants were "associated bodies corporate" within s45 and entitled to rel…