4 Jun 2021
GENIUS EXPRESS LTD v. COLLECTOR OF STAMP REVENUE
- Citation
- [2021] HKDC 659
- Court
- District Court
- Case number
- DCSA43/2013
On the facts the court found an integral, interdependent relationship among the Agreement and the four Assignments such that they formed part of a larger transaction; the stated considerations were artificially suppressed and the 6‑year tenancy/advanced payment arrangements were inserted for the purpose of reducing stamp duty and lacked commercial reality; applying s27(4) and the Ramsay purposive approach the Assignments were treated as voluntary dispositions inter vivos and stamp duty was assessed by reference to the Commissioner’s aggregate valuation of the Property ($15,730,000) at the 3.7…