{"kind":"expression","expression":{"expr_id":"983","doc_id":"983","label":"2022 Revision","is_as_enacted":"f","commenced_on":"2022-01-25","superseded_on":null,"valid_from":"2022-01-25","valid_to":null,"is_current":"t","incorporating":"[\"E3\/2016 Erratum: Land Holding Companies Share Transfer Tax Law (2016 Revision) - GE82\/2016\/p1 - 14-Oct-2016\"]","akn_expr_iri":"\/akn\/ky\/act\/1976\/20\/eng@2022-01-25","akn_envelope":"{\"_canary\": {\"iri\": {\"work\": \"\/akn\/ky\/act\/1976\/20\", \"expression\": \"\/akn\/ky\/act\/1976\/20\/eng@2022-01-25\", \"manifestation\": \"\/akn\/ky\/act\/1976\/20\/eng@2022-01-25.pdf\"}, \"pdf\": {\"md5\": \"2545175c2a657cfe5dcde899be10b7b4\", \"path\": \"\/Users\/q\/kyleg-data\/working\/PRINCIPAL\/1976\/1976-0020\/1976-0020_2022 Revision.pdf\", \"pages\": 16, \"filename\": \"1976-0020_2022 Revision.pdf\"}, \"errors\": [], \"extraction\": {\"model\": null, \"stats\": {\"word_count\": 2891, \"paragraph_count\": 10, \"text_char_count\": 18655}, \"usage\": null, \"method\": \"pymupdf-text\", \"version\": \"kyleg-akn-1.0\", \"extracted_at\": \"2026-06-22\"}, \"classification\": \"text_layer\", \"validation_flags\": [], \"docai_processor_id\": null}, \"akomaNtoso\": {\"act\": {\"body\": [{\"eId\": \"sec_n1\", \"num\": null, \"text\": \"SCHEDULE FEE ENDNOTES Land Holding Companies Share Transfer Tax Act (2022 Revision) LAND HOLDING COMPANIES SHARE TRANSFER TAX ACT (2022 Revision)\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_1\", \"num\": \"1.\", \"text\": \"Short title 1. This Act may be cited as the Land Holding Companies Share Transfer Tax Act (2022 Revision).\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_2\", \"num\": \"2.\", \"text\": \"Definitions 2. In this Act \u2014 \u201ccharitable corporation\u201d means a corporation whose main objects are charitable and which has been certified as such by the Cabinet; \u201ccorporation\u201d includes a partnership, a foreign corporation, a chartered corporation, a mutual fund and a company incorporated under the Companies Act (2022 Revision) but does not include a corporation sole or a charitable corporation; \u201cequity capital\u201d with respect to a corporation includes all shares, stock and scrip whether registered or inscribed which, other than by way of a fixed and predetermined right to interest and repayment of subscribed capital at par, entitles the owner to any variable right of participation in the corporation\u2019s profit, whether by way of dividend, bonus, conversion or distribution upon winding-up; \u201cimmovable property\u201d means immovable property in, on, under or over land in the Cayman Islands including all structures built into or adhering to such land, Land Holding Companies Share Transfer Tax Act (2022 Revision) but does not include tenant\u2019s fixtures, or removable fixtures or power plants installed for the purpose of trade, industry, agriculture or animal husbandry; \u201cland holding\u201d means every legal or beneficial interest in landed property other than such interest held by a legal or equitable mortgagee or chargee by way of bona fide security for the payment of money or money\u2019s worth; \u201cland holding corporation\u201d means a corporation, other than a charitable corporation and such other corporations as the Cabinet may by notice published in the Gazette for the time being specify, which \u2014 (a) is the legal or beneficial owner of any land holding; or (b) is the legal or beneficial owner of any equity capital of a land holding corporation; \u201clanded property\u201d means every legal or beneficial interest in, or claim to or over immovable property whether freehold or leasehold provided that in the case of leasehold property, the original lease was for a term exceeding thirty years; \u201cmarket value\u201d, in relation to landed property, means the estimated amount for which the property should exchange on the date of valuation between a willing buyer and a willing seller in an arm\u2019s-length transaction after proper marketing wherein the parties had each acted knowledgeably, prudently and without compulsion; \u201cmutual fund\u201d has the same meaning as given in section 2 of the Mutual Funds Act (2021 Revision); \u201cpartnership\u201d includes a limited partnership established pursuant to the Partnership Act (2013 Revision) and a general or limited partnership established pursuant to the laws of any other jurisdiction; \u201cshare\u201d includes an interest in a partnership, stock and all other subdivisions of equity capital; \u201ctransfer\u201d includes, in addition to a transfer of shares, every dealing or transaction, whether by the issue of shares, the placement of shares, the grant or take up of any rights, the exchange of shares, the conversion of shares, the grant or exercise of an option or other means howsoever whereby equity capital undergoes a change of beneficial ownership or proportion of ownership or a change occurs in the entitlement or potential entitlement of any person to a share in the distribution of a corporation\u2019s profit or capital.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_3\", \"num\": \"3.\", \"text\": \"Returns, etc., of transfers to be delivered and tax payable 3. (1) Within thirty-one days of any transfer of any equity capital of a land holding corporation such corporation shall deliver to the Minister charged with responsibility for Finance \u2014 (a) the instrument, if any, whereby such transfer is effected; Land Holding Companies Share Transfer Tax Act (2022 Revision) (b) a return in the prescribed form containing the prescribed particulars relating to the corporation, its landed property, the transfer and connected matters; and (c) a sum for the benefit of the revenue \u2014 (i) equivalent to seven and one-half per cent of the consideration for or of the taxable value of the transfer whichever is greater in the case where fifty per cent or more of the market value of the landed property of the land holding corporation is situate in any of the following registration sections, blocks and parcels \u2014 Registration Section Block (A) West Bay 5C, (parcels with water frontage only, but including any parcel subsequently derived from another parcel with water frontage existing at the 9th June, 1997) 5D, 10A, 10E, 11B, 11C, 11D, 12C (parcels with water frontage only, but including any parcel subsequently derived from another parcel with water frontage existing at the 1st July, 2006), 12D, 12E, 17A. (B) George Town 13B, 13C, 13E, 13EH (parcels with road frontage on West Bay Road, Eastern Avenue and North Church Street) 13D (parcels with road frontage on Eastern Avenue) 14BG, 14BH, 14BJ, 14CJ, OPY, 18A; or (ii) equivalent to \u2014 (A) seven and one half per cent of the taxable value of such transfer, if the transferee is a Caymanian; or (B) seven and one half per cent of the taxable value of such transfer, if the transferee is not a Caymanian, in the case where fifty per cent or more of the market value of the landed property of the landed corporation is situate in areas not specified in subparagraph (i). (2) For the purposes of subsection (1)(c)(ii), \u201cCaymanian\u201d means a person who possesses Caymanian status under the repealed Immigration Act (2015 Revision) or any earlier law providing for the same or similar rights, and includes a person who acquired that status under Part 5 of the Immigration (Transition) Act (2022 Revision); Land Holding Companies Share Transfer Tax Act (2022 Revision) (3) For the purposes of this section, the taxable value of a transfer shall be a sum equivalent to the same proportion of the total market value of all the landed property of the relevant corporation at the time of the transfer as the nominal value of the share, or shares, to which the transfer relates bears to the nominal value of the whole of the issued equity capital of the corporation. (4) Where the Minister charged with responsibility for Finance is satisfied that there is a transfer of land holding to or from a land holding corporation and the transfer is, as the case may be, from or to a person or persons who in aggregate are the legal and beneficial owners of not less than forty-five per cent of the shares in the land holding corporation, then the Minister may, in the Minister\u2019s absolute discretion, abate the sum due and payable under the provisions of subsection (1)(c) by such percentage, not being a percentage greater than the aforementioned person or persons percentage holding in the said company, as the Minister shall think fit.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_4\", \"num\": \"4.\", \"text\": \"Transfers between trustees, etc. 4. (1) Section 3 does not apply to \u2014 (a) a transfer effected as a result of a distribution of property by personal representatives acting in that capacity; (b) a transfer effected as a result of the distribution of the estate of a bankrupt; (c) a transfer between trustees or nominees which effects no change in beneficial ownership; or (d) a transfer for natural love and affection \u2014 (i) between parents and children or between spouses or civil partners; or (ii) between children born of the same parent, or between grandparents and grandchildren, where the transfer has been certified by the Minister charged with responsibility for Finance to be a transfer in respect of which that Minister is satisfied that the provisions of this section may properly apply. (2) Section 3 does not apply to a transfer effected as a result of the order of a court, unless the court otherwise directs. (3) To the extent specified in the approval, section 3 does not apply to a landholding company approved by the Minister charged with responsibility for Finance under section 5.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_5\", \"num\": \"5.\", \"text\": \"Approved land holding corporations 5. (1) Subject to this section, the Minister charged with responsibility for Finance, on application made by a land holding corporation, may approve the land holding corporation for the purposes of section 4(3). Land Holding Companies Share Transfer Tax Act (2022 Revision) (2) Approval under subsection (1) shall be in writing and shall be subject to such conditions (if any) as the Minister charged with responsibility for Finance sees fit. (3) The Minister charged with responsibility for Finance shall not approve a land holding corporation under subsection (1) unless that Minister is satisfied that the corporation is in compliance with the following conditions, namely \u2014 (a) that in the case of a land holding corporation which is a mutual fund \u2014 (i) the mutual fund is licensed under the Mutual Funds Act (2021 Revision); (ii) the mutual fund is listed on the Cayman Islands Stock Exchange; (iii) the mutual fund invests exclusively in immovable property in the Islands; and (iv) there are no public interest reasons why the approval should not be granted; and (b) that in the case of any other land holding corporation \u2014 (i) land holding is incidental to the main business of the corporation; (ii) the corporation is listed on a stock exchange approved by the Minister charged with responsibility for Finance; and (iii) there are no public interest reasons why the approval should not be granted. (4) A land holding corporation in respect of which approval has been granted under this section shall, on the anniversary date of the initial grant, submit to the Minister charged with responsibility for Finance an annual declaration that the corporation is in compliance with the conditions of the approval. (5) An annual declaration made by a land holding corporation under subsection (4) shall be signed by two directors of the corporation and shall be accompanied by the annual fee prescribed in the Schedule. (6) The names of land holding corporations approved under this section shall be published in the Gazette. (7) If the Minister charged with responsibility for Finance is of the opinion that a land holding corporation approved under this section has failed \u2014 (a) to comply with a condition of the approval under subsection (2) or (3); (b) to submit an annual declaration under subsection (4); or (c) to submit the annual fee prescribed in the Schedule, the Minister charged with responsibility for Finance may revoke the approval. (8) The Cabinet may, by order, amend the Schedule. Land Holding Companies Share Transfer Tax Act (2022 Revision)\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_6\", \"num\": \"6.\", \"text\": \"Regulations 6. The Cabinet may make regulations prescribing forms and procedures to be used in compliance with this Act.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_7\", \"num\": \"7.\", \"text\": \"Offence of neglecting to make return, etc. 7. (1) A person who being a director, manager or secretary of a land holding corporation, fails to comply with section 3 commits an offence and is liable on summary conviction to a fine of one thousand dollars and to imprisonment for six months; and every land holding corporation in respect of which default under section 3 is made commits an offence and is liable on summary conviction to a fine of one thousand dollars or three times the duty otherwise payable under this Act whichever is the greater. (2) In addition to any liability to a penalty under subsection (1), where any sum required to be paid under section 3 is not fully paid by the due date, the corporation concerned shall be liable to pay interest at the rate of ten per centum per annum for the first month or part of a month and thereafter at the rate of twenty per cent per annum upon the amount for the time being remaining unpaid. (3) Subsection (2) shall apply to any sum that was due under section 3 to be paid by a date earlier than the 1st July, 2006 as though the due date for its payment were the 1st July, 2006.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_8\", \"num\": \"8.\", \"text\": \"Offence of making false statements, etc. 8. A person who makes any return under section 3 or any statement relevant to the liability of any person or corporation thereunder containing matter in the truth of which that person does not believe (proof of their belief being upon the person) commits an offence and is liable on summary conviction to a fine of one thousand dollars and to imprisonment for six months.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_9\", \"num\": \"9.\", \"text\": \"Valuation disputes 9. Should any dispute arise as to the market value of any property for the purpose of compliance with section 3 it shall be settled in the same manner as a stamp duty adjudication under the Stamp Duty Act (2019 Revision) with the same right of appeal from decisions of the Minister charged with responsibility for Finance in that Minister\u2019s capacity of adjudicator. Land Holding Companies Share Transfer Tax Act (2022 Revision) SCHEDULE SCHEDULE FEE Fee to accompany an annual declaration under section 5(5) $5,000.00 Publication in consolidated and revised form authorised by the Cabinet this 11th day of January, 2022. Kim Bullings Clerk of Cabinet Note:  For transitional provisions and validation affecting the 2003 Revision of the Law, as amended by the Land Holding Companies Share Transfer Tax (Amendment) Law, 2006 [Law 17 of 2006] please see sections 7 and 8 of that latter Law. Land Holding Companies Share Transfer Tax Act (2022 Revision) ENDNOTES ENDNOTES Table of Legislation history: SL # Law\/Act # Legislation Commencement Gazette 56\/2020 Citation of Acts of Parliament Act, 2020 3-Dec-2020 LG89\/2020\/s1 35\/2020 Civil Partnership Law, 2020 4-Sep-2020 LG64\/2020\/s1 E3\/2016 Erratum: Land Holding Companies Share Transfer Tax Law (2016 Revision) 2-Sep-2016 GE82\/2016\/p1 Land Holding Companies Share Transfer Tax Law (2016 Revision) 2-Sep-2016 GE69\/2016\/s13 10\/2015 The Land Holding Companies Share Transfer Tax (Amendment) Law, 2015 1-Jul-2015 GE49\/2015\/s4 Land Holding Companies Share Transfer Tax Law (2007 Revision) 23-Jul-2007 G15\/2007\/s6 32\/2006 Land Holding Companies Share Transfer Tax (Amendment) (No.2) Law, 2006 27-Dec-2006 G26\/2006\/s3 17\/2006 Land Holding Companies Share Transfer Tax (Amendment) Law, 2006 1-Jul-2006 GE14\/2006\/s9 28\/2002 Land Holding Companies Share Transfer Tax (Amendment) Law, 2002 10-Feb-2003 G3\/2003\/s1 31\/2001 Land Holding Companies Shared Transfer Tax (Amendment) (Temporary Provisions) Law, 2001 14-Nov-2001 GE28\/2001\/s2 15\/2001 Land Holding Companies Shared Transfer Tax (Amendment) (Variation of Tax) Law, 2001 1-Jun-2001 GE11\/2001\/s19 Land Holding Companies Share Transfer Tax Law (1995 Revision) 20-Mar-1995 G6\/1996\/s6 31\/1993 The Land Holding Companies Share Transfer Tax (Amendment) Law, 1993 14-Dec-1991 GE14Dec\/1993\/s8 18\/1991 The Land Holding Companies Share Transfer Tax (Amendment) Law, 1991 6-Nov-1991 GE6Nov91\/s3 20\/1983 Land Holding Companies Share Transfer Tax (Amendment) Law, 1983 8-Aug-1983 G16\/1983\/s7 25\/1978 Land Holding Companies Share Transfer Tax (Amendment) (No 2.) Law, 1978 18-Dec-1978 G26\/1978\/s4 15\/1978 Land Holding Companies Share Transfer Tax (Amendment) Law, 1978 4-Jul-1978 G14\/1978\/s8 14\/1976 Land Holding Companies Share Transfer Tax Law, 1976 1-Jan-1977 G20\/1976\/s2 ENDNOTES Land Holding Companies Share Transfer Tax Act (2022 Revision) Land Holding Companies Share Transfer Tax Act (2022 Revision) ENDNOTES ENDNOTES Land Holding Companies Share Transfer Tax Act (2022 Revision) (Price: $3.20)\", \"element\": \"section\", \"heading\": null}], \"meta\": {\"notes\": null, \"workflow\": null, \"lifecycle\": {\"source\": \"#cilegis\", \"eventRef\": [{\"eId\": \"e_commence_2022_01_25\", \"date\": \"2022-01-25\", \"type\": \"generation\", \"source\": \"#cilegis\"}]}, \"references\": {\"source\": \"#canary\", \"TLCRole\": [], \"TLCEvent\": [{\"eId\": \"ev_commencement\", \"href\": \"\/akn\/ontology\/canary\/event\/commencement\", \"showAs\": \"commencement\"}], \"TLCPerson\": [], \"TLCConcept\": [{\"eId\": \"inForce\", \"href\": 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ISLANDS\n\nLAND HOLDING COMPANIES SHARE\nTRANSFER TAX ACT\n(2022 Revision)\nSupplement No. 3 published with Legislation Gazette No. 5 of 25th January, 2022.\n\nPage 2\nRevised as at 31st December, 2021\nc\n\nPUBLISHING DETAILS\nLaw 14 of 1976 consolidated with Laws 15 of 1978, 25 of 1978, 20 of 1983, 18 of 1991,\n31 of 1993, 15 of 2001, 31 of 2001, 28 of 2002, 17 of 2006, 32 of 2006, 10 of 2015 and\n35 of 2020 and as amended by Act 56 of 2020.\n\nRevised under the authority of the Law Revision Act (2020 Revision).\n\nOriginally enacted \u2014\nLaw 14 of 1976 -7th September, 1976\nLaw 15 of 1978-15th June, 1978\nLaw 25 of 1978-28th November, 1978\nLaw 20 of 1983-21st June, 1983\nLaw 18 of 1991-11th September, 1991\nLaw 31 of 1993-29th November, 1993\nLaw 15 of 2001-25th May, 2001\nLaw 31 of 2001-14th November, 2001\nLaw 28 of 2002-5th December, 2002\nLaw 17 of 2006-9th June, 2006\nLaw 32 of 2006-10th November, 2006\nLaw 10 of 2015-19th June, 2015\nLaw 35 of 2020-4th September, 2020\nAct 56 of 2020-7th December, 2020.\n\nConsolidated and revised this 31st day of December, 2021.\n\nNote (not forming part of this Act): This revision replaces the 2016 Revision which\nshould now be discarded.\n\nLand Holding Companies Share Transfer Tax Act (2022 Revision)\nArrangement of Sections\n\nc\nRevised as at 31st December, 2021\nPage 3\n\nCAYMAN ISLANDS\n\nLAND HOLDING COMPANIES SHARE\nTRANSFER TAX ACT\n(2022 Revision)\nArrangement of Sections\nSection\nPage\n1.\nShort title ...................................................................................................................................5\n2.\nDefinitions ..................................................................................................................................5\n3.\nReturns, etc., of transfers to be delivered and tax payable .........................................................6\n4.\nTransfers between trustees, etc. ................................................................................................8\n5.\nApproved land holding corporations ...........................................................................................8\n6.\nRegulations ............................................................................................................................. 10\n7.\nOffence of neglecting to make return, etc. ................................................................................ 10\n8.\nOffence of making false statements, etc. ................................................................................. 10\n9.\nValuation disputes ................................................................................................................... 10\nSCHEDULE\n11\nFEE\n11\nENDNOTES\n13\nTable of Legislation history: ............................................................................................................... 13\n\nLand Holding Companies Share Transfer Tax Act (2022 Revision)\nSection 1\n\nc\nRevised as at 31st December, 2021\nPage 5\n\nCAYMAN ISLANDS\n\nLAND HOLDING COMPANIES SHARE\nTRANSFER TAX ACT\n(2022 Revision)\n\n1.\nShort title\n1.\nThis Act may be cited as the Land Holding Companies Share Transfer Tax Act (2022\nRevision).\n2.\nDefinitions\n2.\nIn this Act \u2014\n\u201ccharitable corporation\u201d means a corporation whose main objects are\ncharitable and which has been certified as such by the Cabinet;\n\u201ccorporation\u201d includes a partnership, a foreign corporation, a chartered\ncorporation, a mutual fund and a company incorporated under the Companies\nAct (2022 Revision) but does not include a corporation sole or a charitable\ncorporation;\n\u201cequity capital\u201d with respect to a corporation includes all shares, stock and\nscrip whether registered or inscribed which, other than by way of a fixed and\npredetermined right to interest and repayment of subscribed capital at par,\nentitles the owner to any variable right of participation in the corporation\u2019s\nprofit, whether by way of dividend, bonus, conversion or distribution upon\nwinding-up;\n\u201cimmovable property\u201d means immovable property in, on, under or over land\nin the Cayman Islands including all structures built into or adhering to such land,\n\nSection 3\nLand Holding Companies Share Transfer Tax Act (2022 Revision)\n\nPage 6\nRevised as at 31st December, 2021\nc\n\nbut does not include tenant\u2019s fixtures, or removable fixtures or power plants\ninstalled for the purpose of trade, industry, agriculture or animal husbandry;\n\u201cland holding\u201d means every legal or beneficial interest in landed property other\nthan such interest held by a legal or equitable mortgagee or chargee by way of\nbona fide security for the payment of money or money\u2019s worth;\n\u201cland holding corporation\u201d means a corporation, other than a charitable\ncorporation and such other corporations as the Cabinet may by notice published\nin the Gazette for the time being specify, which \u2014\n(a)\nis the legal or beneficial owner of any land holding; or\n(b) is the legal or beneficial owner of any equity capital of a land holding\ncorporation;\n\u201clanded property\u201d means every legal or beneficial interest in, or claim to or\nover immovable property whether freehold or leasehold provided that in the case\nof leasehold property, the original lease was for a term exceeding thirty years;\n\u201cmarket value\u201d, in relation to landed property, means the estimated amount for\nwhich the property should exchange on the date of valuation between a willing\nbuyer and a willing seller in an arm\u2019s-length transaction after proper marketing\nwherein the parties had each acted knowledgeably, prudently and without\ncompulsion;\n\u201cmutual fund\u201d has the same meaning as given in section 2 of the Mutual Funds\nAct (2021 Revision);\n\u201cpartnership\u201d includes a limited partnership established pursuant to the\nPartnership Act (2013 Revision) and a general or limited partnership established\npursuant to the laws of any other jurisdiction;\n\u201cshare\u201d includes an interest in a partnership, stock and all other subdivisions of\nequity capital;\n\u201ctransfer\u201d includes, in addition to a transfer of shares, every dealing or\ntransaction, whether by the issue of shares, the placement of shares, the grant or\ntake up of any rights, the exchange of shares, the conversion of shares, the grant\nor exercise of an option or other means howsoever whereby equity capital\nundergoes a change of beneficial ownership or proportion of ownership or a\nchange occurs in the entitlement or potential entitlement of any person to a share\nin the distribution of a corporation\u2019s profit or capital.\n3.\nReturns, etc., of transfers to be delivered and tax payable\n3.\n(1) Within thirty-one days of any transfer of any equity capital of a land holding\ncorporation such corporation shall deliver to the Minister charged with\nresponsibility for Finance \u2014\n(a)\nthe instrument, if any, whereby such transfer is effected;\n\nLand Holding Companies Share Transfer Tax Act (2022 Revision)\nSection 3\n\nc\nRevised as at 31st December, 2021\nPage 7\n\n(b) a return in the prescribed form containing the prescribed particulars\nrelating to the corporation, its landed property, the transfer and connected\nmatters; and\n(c)\na sum for the benefit of the revenue \u2014\n(i)\nequivalent to seven and one-half per cent of the consideration for or\nof the taxable value of the transfer whichever is greater in the case\nwhere fifty per cent or more of the market value of the landed\nproperty of the land holding corporation is situate in any of the\nfollowing registration sections, blocks and parcels \u2014\nRegistration Section\nBlock\n(A) West Bay\n5C, (parcels with water frontage only,\nbut including any parcel subsequently\nderived from another parcel with\nwater frontage existing at the 9th\nJune, 1997) 5D, 10A, 10E, 11B, 11C,\n11D, 12C\n(parcels\nwith\nwater\nfrontage only, but including any\nparcel subsequently derived from\nanother parcel with water frontage\nexisting at the 1st July, 2006), 12D,\n12E, 17A.\n(B) George Town\n13B, 13C, 13E, 13EH (parcels with\nroad frontage on West Bay Road,\nEastern Avenue and North Church\nStreet) 13D (parcels with road\nfrontage on Eastern Avenue) 14BG,\n14BH, 14BJ, 14CJ, OPY, 18A; or\n(ii) equivalent to \u2014\n(A) seven and one half per cent of the taxable value of such transfer,\nif the transferee is a Caymanian; or\n(B) seven and one half per cent of the taxable value of such transfer,\nif the transferee is not a Caymanian,\nin the case where fifty per cent or more of the market value of the landed\nproperty of the landed corporation is situate in areas not specified in\nsubparagraph (i).\n(2) For the purposes of subsection (1)(c)(ii), \u201cCaymanian\u201d means a person who\npossesses Caymanian status under the repealed Immigration Act (2015\nRevision) or any earlier law providing for the same or similar rights, and\nincludes a person who acquired that status under Part 5 of the Immigration\n(Transition) Act (2022 Revision);\n\nSection 4\nLand Holding Companies Share Transfer Tax Act (2022 Revision)\n\nPage 8\nRevised as at 31st December, 2021\nc\n\n(3) For the purposes of this section, the taxable value of a transfer shall be a sum\nequivalent to the same proportion of the total market value of all the landed\nproperty of the relevant corporation at the time of the transfer as the nominal\nvalue of the share, or shares, to which the transfer relates bears to the nominal\nvalue of the whole of the issued equity capital of the corporation.\n(4) Where the Minister charged with responsibility for Finance is satisfied that there\nis a transfer of land holding to or from a land holding corporation and the\ntransfer is, as the case may be, from or to a person or persons who in aggregate\nare the legal and beneficial owners of not less than forty-five per cent of the\nshares in the land holding corporation, then the Minister may, in the Minister\u2019s\nabsolute discretion, abate the sum due and payable under the provisions of\nsubsection (1)(c) by such percentage, not being a percentage greater than the\naforementioned person or persons percentage holding in the said company, as\nthe Minister shall think fit.\n4.\nTransfers between trustees, etc.\n4.\n(1) Section 3 does not apply to \u2014\n(a)\na transfer effected as a result of a distribution of property by personal\nrepresentatives acting in that capacity;\n(b) a transfer effected as a result of the distribution of the estate of a bankrupt;\n(c)\na transfer between trustees or nominees which effects no change in\nbeneficial ownership; or\n(d) a transfer for natural love and affection \u2014\n(i)\nbetween parents and children or between spouses or civil partners; or\n(ii) between children born of the same parent, or between grandparents\nand grandchildren, where the transfer has been certified by the\nMinister charged with responsibility for Finance to be a transfer in\nrespect of which that Minister is satisfied that the provisions of this\nsection may properly apply.\n(2) Section 3 does not apply to a transfer effected as a result of the order of a court,\nunless the court otherwise directs.\n(3) To the extent specified in the approval, section 3 does not apply to a landholding\ncompany approved by the Minister charged with responsibility for Finance\nunder section 5.\n5.\nApproved land holding corporations\n5.\n(1) Subject to this section, the Minister charged with responsibility for Finance, on\napplication made by a land holding corporation, may approve the land holding\ncorporation for the purposes of section 4(3).\n\nLand Holding Companies Share Transfer Tax Act (2022 Revision)\nSection 5\n\nc\nRevised as at 31st December, 2021\nPage 9\n\n(2) Approval under subsection (1) shall be in writing and shall be subject to such\nconditions (if any) as the Minister charged with responsibility for Finance sees\nfit.\n(3) The Minister charged with responsibility for Finance shall not approve a land\nholding corporation under subsection (1) unless that Minister is satisfied that the\ncorporation is in compliance with the following conditions, namely \u2014\n(a)\nthat in the case of a land holding corporation which is a mutual fund \u2014\n(i)\nthe mutual fund is licensed under the Mutual Funds Act (2021\nRevision);\n(ii) the mutual fund is listed on the Cayman Islands Stock Exchange;\n(iii) the mutual fund invests exclusively in immovable property in the\nIslands; and\n(iv) there are no public interest reasons why the approval should not be\ngranted; and\n(b) that in the case of any other land holding corporation \u2014\n(i)\nland holding is incidental to the main business of the corporation;\n(ii) the corporation is listed on a stock exchange approved by the\nMinister charged with responsibility for Finance; and\n(iii) there are no public interest reasons why the approval should not be\ngranted.\n(4) A land holding corporation in respect of which approval has been granted under\nthis section shall, on the anniversary date of the initial grant, submit to the\nMinister charged with responsibility for Finance an annual declaration that the\ncorporation is in compliance with the conditions of the approval.\n(5) An annual declaration made by a land holding corporation under subsection (4)\nshall be signed by two directors of the corporation and shall be accompanied by\nthe annual fee prescribed in the Schedule.\n(6) The names of land holding corporations approved under this section shall be\npublished in the Gazette.\n(7) If the Minister charged with responsibility for Finance is of the opinion that a\nland holding corporation approved under this section has failed \u2014\n(a)\nto comply with a condition of the approval under subsection (2) or (3);\n(b) to submit an annual declaration under subsection (4); or\n(c)\nto submit the annual fee prescribed in the Schedule,\nthe Minister charged with responsibility for Finance may revoke the approval.\n(8) The Cabinet may, by order, amend the Schedule.\n\nSection 6\nLand Holding Companies Share Transfer Tax Act (2022 Revision)\n\nPage 10\nRevised as at 31st December, 2021\nc\n\n6.\nRegulations\n6.\nThe Cabinet may make regulations prescribing forms and procedures to be used in\ncompliance with this Act.\n7.\nOffence of neglecting to make return, etc.\n7.\n(1) A person who being a director, manager or secretary of a land holding\ncorporation, fails to comply with section 3 commits an offence and is liable on\nsummary conviction to a fine of one thousand dollars and to imprisonment for\nsix months; and every land holding corporation in respect of which default under\nsection 3 is made commits an offence and is liable on summary conviction to a\nfine of one thousand dollars or three times the duty otherwise payable under this\nAct whichever is the greater.\n(2) In addition to any liability to a penalty under subsection (1), where any sum\nrequired to be paid under section 3 is not fully paid by the due date, the\ncorporation concerned shall be liable to pay interest at the rate of ten per centum\nper annum for the first month or part of a month and thereafter at the rate of\ntwenty per cent per annum upon the amount for the time being remaining\nunpaid.\n(3) Subsection (2) shall apply to any sum that was due under section 3 to be paid by\na date earlier than the 1st July, 2006 as though the due date for its payment were\nthe 1st July, 2006.\n8.\nOffence of making false statements, etc.\n8.\nA person who makes any return under section 3 or any statement relevant to the\nliability of any person or corporation thereunder containing matter in the truth of\nwhich that person does not believe (proof of their belief being upon the person)\ncommits an offence and is liable on summary conviction to a fine of one thousand\ndollars and to imprisonment for six months.\n9.\nValuation disputes\n9.\nShould any dispute arise as to the market value of any property for the purpose of\ncompliance with section 3 it shall be settled in the same manner as a stamp duty\nadjudication under the Stamp Duty Act (2019 Revision) with the same right of appeal\nfrom decisions of the Minister charged with responsibility for Finance in that\nMinister\u2019s capacity of adjudicator.\n\nLand Holding Companies Share Transfer Tax Act (2022 Revision)\n\nSCHEDULE\n\nc\nRevised as at 31st December, 2021\nPage 11\n\n SCHEDULE\nFEE\nFee to accompany an annual declaration under section 5(5)\n\n$5,000.00\n\nPublication in consolidated and revised form authorised by the Cabinet this 11th\nday of January, 2022.\nKim Bullings\nClerk of Cabinet\n\nNote:  For transitional provisions and validation affecting the 2003 Revision of the Law,\nas amended by the Land Holding Companies Share Transfer Tax (Amendment) Law, 2006\n[Law 17 of 2006] please see sections 7 and 8 of that latter Law.\n\nLand Holding Companies Share Transfer Tax Act (2022 Revision)\n\nENDNOTES\n\nc\nRevised as at 31st December, 2021\nPage 13\n\nENDNOTES\nTable of Legislation history:\nSL #\nLaw\/Act #\nLegislation\nCommencement\nGazette\n\n56\/2020\nCitation of Acts of Parliament Act, 2020\n3-Dec-2020\nLG89\/2020\/s1\n\n35\/2020\nCivil Partnership Law, 2020\n4-Sep-2020\nLG64\/2020\/s1\nE3\/2016\n\nErratum: Land Holding Companies Share Transfer Tax\nLaw (2016 Revision)\n2-Sep-2016\nGE82\/2016\/p1\n\nLand Holding Companies Share Transfer Tax Law (2016\nRevision)\n2-Sep-2016\nGE69\/2016\/s13\n\n10\/2015\nThe Land Holding Companies Share Transfer Tax\n(Amendment) Law, 2015\n1-Jul-2015\nGE49\/2015\/s4\n\nLand Holding Companies Share Transfer Tax Law (2007\nRevision)\n23-Jul-2007\nG15\/2007\/s6\n\n32\/2006\nLand Holding Companies Share Transfer Tax\n(Amendment) (No.2) Law, 2006\n27-Dec-2006\nG26\/2006\/s3\n\n17\/2006\nLand Holding Companies Share Transfer Tax\n(Amendment) Law, 2006\n1-Jul-2006\nGE14\/2006\/s9\n\n28\/2002\nLand Holding Companies Share Transfer Tax\n(Amendment) Law, 2002\n10-Feb-2003\nG3\/2003\/s1\n\n31\/2001\nLand Holding Companies Shared Transfer Tax\n(Amendment) (Temporary Provisions) Law, 2001\n14-Nov-2001\nGE28\/2001\/s2\n\n15\/2001\nLand Holding Companies Shared Transfer Tax\n(Amendment) (Variation of Tax) Law, 2001\n1-Jun-2001\nGE11\/2001\/s19\n\nLand Holding Companies Share Transfer Tax Law (1995\nRevision)\n20-Mar-1995\nG6\/1996\/s6\n\n31\/1993\nThe Land Holding Companies Share Transfer Tax\n(Amendment) Law, 1993\n14-Dec-1991 GE14Dec\/1993\/s8\n\n18\/1991\nThe Land Holding Companies Share Transfer Tax\n(Amendment) Law, 1991\n6-Nov-1991\nGE6Nov91\/s3\n\n20\/1983\nLand Holding Companies Share Transfer Tax\n(Amendment) Law, 1983\n8-Aug-1983\nG16\/1983\/s7\n\n25\/1978\nLand Holding Companies Share Transfer Tax\n(Amendment) (No 2.) Law, 1978\n18-Dec-1978\nG26\/1978\/s4\n\n15\/1978\nLand Holding Companies Share Transfer Tax\n(Amendment) Law, 1978\n4-Jul-1978\nG14\/1978\/s8\n\n14\/1976\nLand Holding Companies Share Transfer Tax Law, 1976\n1-Jan-1977\nG20\/1976\/s2\n\nENDNOTES\nLand Holding Companies Share Transfer Tax Act (2022 Revision)\n\nPage 14\nRevised as at 31st December, 2021\nc\n\nLand Holding Companies Share Transfer Tax Act (2022 Revision)\n\nENDNOTES\n\nc\nRevised as at 31st December, 2021\nPage 15\n\nENDNOTES\nLand Holding Companies Share Transfer Tax Act (2022 Revision)\n\nPage 16\nRevised as at 31st December, 2021\nc\n\n(Price: $3.20)","akn_extracted_at":"2026-06-22 15:37:37.382746+00","cms_id":"1976-0020","law_type":"principal","year":"1976","number":"20","title":"Stamp Duty (Appeal) Rules","status":"in_force"},"provenance":{"files":[{"file_id":"6075","expr_id":"983","kind":"akn_xml","filename":"1976-0020_2022 Revision.akn.xml","source_url":null,"storage_path":"\/Users\/q\/kyleg-data\/working\/PRINCIPAL\/1976\/1976-0020\/1976-0020_2022 Revision.akn.xml","content_md5":"36c43140307ef534e31dfd7c2f7f5b81","byte_size":"18944","http_last_modified":null,"fetched_at":"2026-06-22 15:37:37.508879+00"},{"file_id":"1965","expr_id":"983","kind":"pristine_pdf","filename":"1976-0020_2022 Revision.pdf","source_url":"\/cms\/images\/LEGISLATION\/PRINCIPAL\/1976\/1976-0020\/1976-0020_2022 Revision.pdf","storage_path":"\/Users\/q\/kyleg-data\/pristine\/PRINCIPAL\/1976\/1976-0020\/1976-0020_2022 Revision.pdf","content_md5":"2545175c2a657cfe5dcde899be10b7b4","byte_size":"1005621","http_last_modified":null,"fetched_at":"2026-06-21 23:09:35.730378+00"},{"file_id":"1966","expr_id":"983","kind":"working_pdf","filename":"1976-0020_2022 Revision.pdf","source_url":"\/cms\/images\/LEGISLATION\/PRINCIPAL\/1976\/1976-0020\/1976-0020_2022 Revision.pdf","storage_path":"\/Users\/q\/kyleg-data\/working\/PRINCIPAL\/1976\/1976-0020\/1976-0020_2022 Revision.pdf","content_md5":"2545175c2a657cfe5dcde899be10b7b4","byte_size":"1005621","http_last_modified":null,"fetched_at":"2026-06-21 23:09:35.730378+00"}],"paragraph_count":31,"latest_history":null},"quality":{"expr_id":"983","doc_id":"983","quality_state":"known_issue","quality_score":"59","needs_human_review":"t","deterministic_categories":"{duplicate_text,page_header_footer_noise,title_mismatch}","llm_categories":"{truncated_text,other}","repair_actions":"{collapse_duplicate_text,manual_review,reextract_full_text,strip_page_furniture,verify_title_metadata}","finding_severity_counts":"{\"low\": 1, \"medium\": 1}","finding_summary":"Extraction appears mostly complete but requires verification of truncated section and removal of stray metadata.","assessed_at":"2026-06-22 15:29:45.325656+00","updated_at":"2026-06-22 15:29:45.325656+00"}}