20 Aug 1999
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 Appeal
- Case number
- CACV199/1998
By majority the Court held that the pre-ordained composite transactions contained intermediary steps that had no commercial purpose apart from avoidance of estate duty and therefore those steps were to be disregarded under the Ramsay principle; the true end result was an effective inter vivos disposition of Hong Kong-situate property to offshore trustees within three years of death and the transfers were chargeable to estate duty.