Hong Kong court decision in Arrowtown - unrestricted purposive interpretation prevails

In the case of The Collector of Stamp Revenue v. Arrowtown Assets Limited, the Hong Kong Court of Final Appeal decided that certain corporate stock should be disregarded in applying the law to the taxpayer's case because the stock had been issued for tax avoidance purposes. The Arrowtown decision has significance far beyond the scope of Kong Kong stamp duty jurisprudence. This article first discusses briefly the case law background and then summarizes the facts of the Arrowtown case and analyses the judgment of the Hong Kong Court of Final Appeal.