Arrowtown Assets Ltd v. The Collector of Stamp Revenue

CACV0001180/2002

CACV 118/2002

IN THE HIGH COURT OF THE

HONG KONG SPECIAL ADMINISTRATIVE REGION

COURT OF APPEAL

CIVIL APPEAL NO. 118 OF 2002

(ON APPEAL FROM DCSA 52 OF 2000)

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CORRIGENDUM

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Kindly note the following corrections in the Judgment of the above case handed down by the Court of Appeal on 17 March 2003:

Para. 221, lines M -O,

the opening bracket before the word "contained" be deleted, [44], [50] & [51] be deleted and substituted with [210], [216] and [217] respectively so that the first 7 lines in paragraph 221 should read as :

221. In contrast, however, sometimes terms in tax legislation do not have a broad commercial meaning. It is crucial to bear this in mind because in this situation, the innovation introduced by the Ramsay Principle contained in Lord Brightman's words in Furniss v Dawson (see paragraphs [210] and [216] above) has little, if any, application. Lord Hoffmann put the matter in this way in his speech in Macniven at paragraph 49 (following on from the passage I have given in paragraph [217] above ) (393C-E):-

Dated 13th August 2003