### Stamp Duty Ordinance 《印花稅條例》

47C. Interpretation
(1) In this Part, subject to subsection (2), an expression specified below has the same meaning as it has in Schedule 17A to the Inland Revenue Ordinance (Cap. 112)—
alternative bond (另類債券) 
arrangements performed according to terms condition (按條款履行安排條件) 
asset transaction between O and BU (發起人——業務實體資產交易) 
bond arrangement (債券安排) 
bond arrangement as financial liability condition (債券安排作金融負債條件) 
bond-holder (持債人) 
bond-issuer (發債人) 
bond-issuer as conduit condition (發債人作轉付者條件) 
Hong Kong connection condition (與香港關連條件) 
investment arrangement (投資安排) 
investment arrangement as financial liability condition (投資安排作金融負債條件) 
investment return (投資回報) 
maximum term length condition (最長年期條件) 
originator (發起人) 
reasonable commercial return condition (合理商業回報條件) 
specified alternative bond scheme (指明另類債券計劃) 
specified asset (指明資產) 
specified asset transaction between O and BI (發起人——發債人指明資產交易) 
specified investment arrangement (指明投資安排) 
specified term (指明年期) 
(2) For the purposes of the definitions of bond-issuer as conduit condition 

47D. Qualified bond arrangement, and qualified investment arrangement, in specified alternative bond scheme
(1) The bond arrangement in a specified alternative bond scheme is a qualified bond arrangement 

47E. Alternative bond under qualified bond arrangement regarded as bond
For the purposes of this Ordinance—
(a) the bond-holders under a qualified bond arrangement in a specified alternative bond scheme are to be regarded as not having any legal or beneficial interest in the specified asset under the specified alternative bond scheme; and
(b) an alternative bond issued under such a qualified bond arrangement is to be regarded as a bond to which neither paragraph (b) nor (c) of the definition of loan capital 

### Stamp Duty Ordinance 《印花稅條例》

47F. Relief on transactions under qualified investment arrangement
(1) Subject to sections 47H, 47I and 47L, an instrument is not chargeable with stamp duty under head 1(1), 1(1AA), 1(1AAB), 1(1A), 1(1B), 1(1C), 1(2), 2(1), 2(3) or 2(4) in the First Schedule or under section 29D(2)(a) if the requirements under subsections (2) and (3) are complied with in relation to the instrument. (Amended 2 of 2014 s. 17)
(2) It must be shown to the satisfaction of the Collector that—
(a) the instrument is executed under a qualified investment arrangement in a specified alternative bond scheme either—
(i) to effect a transaction that is a specified asset transaction between O and BI or an asset transaction between O and BU under that qualified investment arrangement (IA transaction

### Stamp Duty Ordinance 《印花稅條例》

47G. Relief resulting from modification of sections 29CA and 29DA in relation to property held, or formerly held, under qualified investment arrangement
(1) Sections 29CA and 29DA apply, with the modifications specified in Schedule 6, to an agreement for sale or a conveyance on sale if it is shown to the satisfaction of the Collector that—
(a) the agreement or conveyance falls within section 1 of that Schedule; and
(b) the requirements under subsection (2) or (3) are complied with.
(2) If the operation of subsection (1) will result in the agreement or conveyance not being chargeable with special stamp duty under head 1(1B) or 1(1AA) in the First Schedule, security must be given to the satisfaction of the Collector for the payment of—
(a) the special stamp duty that, but for subsection (1), would have been chargeable on the agreement or conveyance; and
(b) other amounts that, but for subsection (1), would have been payable under this Ordinance.
(3) If the operation of subsection (1) will result in the agreement or conveyance being chargeable with special stamp duty under head 1(1B) or 1(1AA) in the First Schedule of an amount that is less than the amount that would have been chargeable but for subsection (1), security must be given to the satisfaction of the Collector for the payment of—
(a) the amount by which the special stamp duty chargeable will be reduced by the operation of subsection (1); and
(b) the excess of the amounts (other than the special stamp duty) that, but for subsection (1), would have been payable under this Ordinance over the amounts (other than the special stamp duty) that will be payable with the operation of subsection (1).
(4) In this Ordinance, a reference to relief granted under this section for an agreement for sale or a conveyance on sale is a reference to the fact that the agreement or conveyance is stamped on the basis—
(a) that the agreement or conveyance is not chargeable with special stamp duty under head 1(1B) or 1(1AA) in the First Schedule because of subsection (1); or
(b) that the agreement or conveyance is chargeable with special stamp duty under head 1(1B) or 1(1AA) in the First Schedule of an amount that is less than the amount that would have been chargeable, but for subsection (1).

### Stamp Duty Ordinance 《印花稅條例》

47H. Relief granted under section 47F or 47G deemed withdrawn
(1) This section applies if—
(a) a claim for relief from stamp duty has been made under section 47F or 47G for any instrument, alleging that—
(i) an arrangement (alleged qualified investment arrangement

47I. Instrument to be duly stamped
An instrument to which section 47F(1) or 47G(1) applies is not duly stamped unless—
(a) it is stamped with the stamp duty with which it would be chargeable but for section 47F or 47G; or
(b) it has, in accordance with section 13, been stamped with a particular stamp or by way of a stamp certificate, denoting either that it is not chargeable with any stamp duty or that it is duly stamped.

47J. Records and returns
(1) This section applies to a person (specified person

47K. Offence in respect of false or misleading information
(1) A person commits an offence if—
(a) the person, with intent to defraud the Government of any stamp duty, causes or allows—
(i) an entry to be made in the books and records kept under section 47J; or
(ii) particulars to be furnished in a return made under section 47J; and
(b) the entry or particulars are false or misleading in a material respect.
(2) A person who commits an offence under this section is liable for the fine and imprisonment specified in section 60.