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Obtaining Stamp Duty Relief under Section 45 for Structures Involving a Partnership — A Possibility?

Among the various taxes and duties administered and collected by the Hong Kong Inland Revenue Department (IRD), over the past five years stamp duty has been one of the top three contributors to the revenue of the Hong Kong Government. Stamp duty is charged on documents. In Hong Kong, the governing legislation of stamp duty is the Stamp Duty Ordinance (SDO) (Chapter 117). Its charging scope includes, inter alia, a conveyance on sale of immovable property in Hong Kong and a transfer of Hong Kong stock.