Stamp Duty (Amendment) (No. 3) Bill 2026 to be gazetted
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According to the Stamp Duty Ordinance, stamp duty relief is provided for the transfer of immovable property or Hong Kong stock between associated bodies corporate. Currently, if one of two bodies corporate owns 90 per cent or above of the issued share capital of another, or a third body corporate owns 90 per cent or above of the issued share capital of each of them, relevant bodies corporate would be regarded as associated. The Bill will relax the criteria in determining whether two bodies corporate are associated, taking into account other direct or indirect beneficial interests or voting rights in addition to issued share capital, and lowering the ownership threshold to 75 per cent.
A Government spokesperson said, "Since some new enterprises, such as limited liability partnerships and companies limited by guarantee, etc, do not issue shares, other enterprises may exercise ownership in these enterprises through direct or indirect beneficial interests such as equity interests or participation interests. The Bill relaxes the definition of associated bodies corporate, enabling these new enterprises to also benefit from the stamp duty relief for intra-group asset transfers.
"Business expansion and restructuring frequently involve the transfer of assets within a business group. The Bill enables more enterprises to benefit from the relevant stamp duty relief, which will further enhance the business environment, thereby increasing the competitiveness of Hong Kong's tax regime."
The Bill will be introduced into the Legislative Council for first reading and the commencement of the second reading debate on October 14. Subject to passage by the Legislative Council, it will apply to the instruments executed on or after February 25 this year.
Ends/Tuesday, September 29, 2026
Issued at HKT 17:30
Issued at HKT 17:30
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