18 Jun 1998
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 First Instance
- Case number
- HCMP1282/1997
Although the Ramsay principle is applicable in principle, on the facts the transfers were genuine sales, loans and trust/unit transactions with genuine non‑fiscal purposes; the associated operations provision does not convert offshore proceeds or units into Hong Kong situs property, the loans were not shams or self‑cancelling, and therefore there was no disposition of Hong Kong property caught by the estate duty charging provisions; declaration for plaintiffs granted.