16 Jun 2025
John Wiley & Sons UK2 LLP & Anor v. The Collector of Stamp Revenue
- Citation
- [2025] HKCFA 11
- Court
- Court of Final Appeal
- Case number
- FACV11/2024
Section 45 must be read to require "issued share capital" in its company law sense; an LLP cannot issue share capital and therefore cannot satisfy the statute's association condition; the Share Transfer was not exempt under s 45 and the appeal fails.