Read the full judgment text of CACV 23/2023 on BabelCite. This Court of Appeal judgment was delivered on 5 July 2024.
1. The issue which arises for determination in this appeal is whether Wiley International LLC (“ HoldCo ”), which holds, indirectly, the entire beneficial interest in John Wiley & Sons UK2 LLP (“ LLP 2 ”), a limited liability partnership registered in the United Kingdom, should be regarded as the beneficial owner of not less than 90 per cent of the “issued share capital” of LLP 2 for the purpose of claiming stamp duty relief under Section 45(2) of the Stamp Duty Ordinance, Cap 117 (“ the Ordinan
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