THE UNIVERSITY OF HONG KONG

FACULTY OF BUSINESS AND ECONOMICS

ACCT3107 – Hong Kong Taxation

Tutorial Questions
Unit 13 – Stamp Duty

All the properties covered in this question are situated in Hong Kong.

Part A

Determine the special stamp duty (SSD) liability upon selling the property under each of the
following three scenarios (ignore the stamp duty liability under Head 1(1) and Head 1(1A) and
any buyer’s stamp duty (BSD) liability in your calculations):

(i) Mr. A purchased a residential property at the price of $4,000,000 on 28 September 2010. He
sold the property for $4,500,000 on 10 January 2011.

(ii) Mr. B purchased a residential property at the price of 3,000,000 on 15 March 2011. He sold
the property for $3,800,000 on 15 April 2012.

(iii) Mr. C purchased a residential property at the price of $6,000,000 on 29 October 2017 He
sold the property for $6,900,000 on 4 February 2018.

(iv) Mr. D purchased a residential property at the price of $8,000,000 on 12 April 2018. He sold
the property for $8,800,000 on 15 March 2019.

Part B

Determine the buyer’s stamp duty (BSD) liability for each of the following transactions (ignore
the stamp duty liability under Head 1(1) and Head 1(1A) and any SSD payable in your
calculations):

(i) Mr. Chan purchased a residential property at the price of $4,500,000 on 5 March 2018. He
sold the property to Mr. Wong, a non Hong Kong permanent resident (non-HKPR), for
$5,100,000 on 10 January 2019.

(ii) Mr. Sze, a Hong Kong permanent resident (HKPR), and his spouse, a non-HKPR, jointly
purchased a residential property at the price of $3,600,000 on 1 December 2018.

(iii) Mr. Lee, a HKPR and Mr. Chan, a non-HKPR, jointly purchased a residential property on
15 April 2019 at a price of $10M. Mr. Lee and Mr. Chan are not close relatives.
Part C
(i) Mr. Fung, a HKPR, owns a residential property (the first property) in Hong Kong. On 1
July 2013, he entered into a provisional agreement for sale and purchase (PS&P) to acquire
another residential property (the second property) at the purchase price of $30M. The
formal agreement for sale and purchase (S&P) was signed on 30 July 2013. Determine the
amount of stamp duty chargeable under Head 1(1) and Head 1(1A) of the Stamp Duty
Ordinance for the acquisition of the second property.

(ii) Same facts as Part C (i), but Mr. Fung entered into the provisional agreement for sale and
purchase to acquire another residential property on 8 November 2016. The formal
agreement for sale and purchase was signed on 30 November 2016. How would your
answer be different from Part C (i)?

(iii) Mr. Ho, a HKPR, purchased a residential property on 20 April 2018 at a purchase price of
$12M. Mr. Ho does not own any other residential property in Hong Kong. What is the
amount of ad valorem stamp duty (AVD) payable?
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Stamp Duty Rates (extracted from page 2 of Unit 13A)
Conveyance with consideration Rate (Scale 1) # Rate (Scale 2)
w.e.f. 23 Feb 2013 w.e.f. 1 April 2010
Up to $2,000,000 * 1.50% $100
$2,000,001 - $3,000,000 * 3.00% 1.50%
$3,000,001 - $4,000,000 * 4.50% 2.25%
$4,000,001 - $6,000,000 * 6.00% 3.00%
$6,000,001 - $20,000,000* 7.50% 3.75%
Over $20,000,000 * 8.50% 4.25%
* subject to marginal relief
# Flat rate of 15% (w.e.f. 5 November 2016) for residential properties

Special Stamp Duty (SSD): SSD Rate (A) SSD Rate (B)
Holding Period (where applicable) (where applicable)
6 months or less 15% 20%
> 6 months to 12 months 10% 15%
> 12 months to 24 months 5% 10%
> 24 months to 36 months - 10%
(A): For property acquired on or after 20 November 2010 to 26 October 2012
(B): For property acquired on or after 27 October 2012

Buyer’s Stamp Duty (BSD) 15% (w.e.f. 27 October 2012, where applicable)