22 Nov 2001
ARROWTOWN ASSETS LTD. v. THE COLLECTOR OF STAMP REVENUE
- Citation
- ARROWTOWN ASSETS LTD. v. THE COLLECTOR OF STAMP REVENUE
- Court
- District Court
- Case number
- DCSA52/2000
The DC Agreement formed part of the consideration for the land assignment and included contractual promises by Calm Seas (an outsider) (notably clause 14), thereby infringing s.45(4)(a); the Loan Note was to be parted with pursuant to the Share Sale Agreement in consequence of transactions involving payment by an outsider, infringing s.45(5); the Ramsay approach did not permit disregarding the issued deferred shares because the statutory concept of 'issued share capital' and 'associated body corporate' are legal concepts and the shares were legally valid; accordingly intra-group relief under…