4 Jun 2021
LAND CONCEPT LTD v. COLLECTOR OF STAMP REVENUE
- Citation
- [2021] HKDC 659
- Court
- District Court
- Case number
- DCSA9/2012
The court found the four conveyances were interdependent parts of a larger transaction, the alleged 6-year tenancies and advance rental payments were contrived and lacked commercial reality, applied the Ramsay purposive approach and s27(4) to deem the stated considerations inadequate, accepted the Commissioner’s aggregate valuation of the Property ($15,730,000) and held stamp duty is chargeable at the higher ad valorem rate (3.75%) on that valuation with resulting refunds as calculated by the Collector.