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Hong Kong Matrimonial Finance Law – Enamoured by Big Banking?

Updated: Feb 13

Alexander Clevewood Ng*


The way the law treats parties in a matrimonial finance case reflects the priorities of a society.


For instance, in a post-Pettkus reality in Canada,[1] the imposition of a restitution-based resulting trust in dividing proprietary interests after separation indicates a shift to a more contribution-based, and ultimately, individualistic approach. The tenacity upon which English law adheres to the common intention construction trust in parallel scenarios indicates a greater focus on the ‘venture’ between the two parties.


A recent case in Hong Kong jurisprudence revealed the increasing significance of commerciality in matrimonial cases. It was decided by the Hong Kong District Court (‘HKDC’).[2] Where a married couple was living in a mortgaged property, one of which having become insolvent, the other might not be able to exercise any right of redemption attached to the property. The bank could therefore exercise foreclosure.


Although this decision was overruled by the Hong Kong Court of Appeal (‘HKCA’), the mere fact that the lower courts prioritised commerciality when adjudicating familial cases sparks concern. Access to justice is not free. There are reasonably similar cases which do not attract the attention of the HKCA. Furthermore, it is questionable whether, in its reasoned judgment, the HKCA did put this notion to bed.


However, this sparks a broader question: Should the HKCA do so, given that the law reflects societal values? Indeed, commerciality may mean more in some societies than others.


This article is organised into four parts. Part I provides a summary of the case. In Part II, it criticises the reasoning adopted by the HKDC. Part III summarises the reasoning of the HKCA and evaluates the extent to which it overruled the HKDC’s reasoning. Part IV is the conclusion.


As a side note, the HKDC judgment is only available in Traditional Chinese. The HKCA judgment is available in English. This is also not a traditional case note.


Part I. Case Summary

A.    Factual Background


The two defendants, Mr Lee Yau Tak (‘Mr Lee’) and Ms Chan Wan Ying (‘Ms Chan’) had been married until 2015. They decided to purchase a new property as their matrimonial home (‘the Property’) in 2012. The purchase price was approximately HK$2,000,000.


Mr Lee took out a mortgage with the Shanghai Commercial Bank (‘the Bank’) valued at HK$700,000 at the time. In addition, Mr Lee borrowed a sum of HK$1,310,935 from the government. These sums were sufficient in purchasing the Property. Although Ms Chan borrowed HK$200,000 on behalf of her husband from her brother-in-law, intending for said sum to be used towards the purchase, it was ultimately not required.


In 2016, Mr Lee declared bankruptcy. The Bank applied for foreclosure of the Property.


B.    Legal Background


Mr Lee was the sole legal owner of the Property. Since equity follows the law, he was presumed to be the sole beneficial owner as well.[3]


However, during the proceedings, Ms Chan wished to maintain mortgage payments to avoid foreclosure. She argued that she had an interest in the Property. Since her name was not used for the purchase, at most, she could claim a beneficial interest. According to Hong Kong law, this may arise from a common intention constructive trust. A holistic approach is propounded by Primecredit Ltd v Yeung Chun Pang Barry,[4] which mirrors the approach in England and Wales.[5] This would displace the presumption stated in the preceding paragraph. This is elaborated in greater detail in Part II.


This interest might encompass the equity of redemption as a result of the mortgage. Alternatively, the trustees in bankruptcy (‘the Trustees’) could transfer or sell the equity of redemption to Ms Chan, having assessed that this concorded with the best interests of other creditors.[6]


A potential issue was whether Ms Chan had an overriding interest which would prevent the Bank from seeking foreclosure. This issue was academic since it was admitted at trial that the Bank’s interest took precedence. It could be briefly dealt with in this context.


In Abbey National Building Society v Cann,[7] it was held that the mortgagee’s interest should always take precedence over any beneficial ownership that arose upon the purchase of matrimonial property, even if the beneficial owner made financial contributions. The same conclusion was reached by the District Court judge after referring to authorities in common law jurisdictions.[8]


However, Cann is not authority for any priority issues arising from the contention between the second defendant’s equity of redemption and the interests of creditors in an insolvency situation. Alternatively, since English caselaw is only persuasive in Hong Kong courts, it can either be departed or distinguished.


C.    Procedural Background


This case was decided by the HKDC, culminating in a judgment published on 8 October 2020. The HKDC ruled in favour of the Bank.


The two main issues in contention were:


(1)   Whether Ms Chan had any interest in the Property; and

(2)   Whether Ms Chan could exercise the equity of redemption to redeem the mortgage.


This decision was appealed to the HKCA. The appeal was allowed in Ms Chan’s favour on both issues in March 2023.


Part II. Critique of the HKDC Judgment

The judge erred on both legal issues and general fact-finding. The first two subsections contain (1) what the judge decided on the point and (2) why it is submitted to be wrong.


Ground 1: Common Intention Constructive Trust

In [33] of the judgment,[9] the judge concluded that there was insufficient evidence to declare a common intention constructive trust over the Property.


Two reasons were advanced to support this determination:


(1)   There was insufficient evidence to suggest any express common intention to hold the Property in favour of both Ms Chan and Mr Lee;


(2)   Ms Chan had not made any direct financial contributions to the acquisition of the Property. Her being married to Mr Lee at the time of the purchase did not give rise to the presumption that she was a beneficial owner.


Both reasons are discordant with Hong Kong jurisprudence and should be rejected.


As mentioned in Part I, Primecredit Ltd v Yeung Chun Pang Barry incorporated the holistic approach in Stack v Dowden[10] in determining whether a common intention constructive trust should be declared over a matrimonial home.


Common intentions can either be express or inferred. Inference is made using a holistic approach, which may involve, but not necessarily, financial contributions.[11] This analysis is applicable for both the establishment of beneficial ownership and its quantification, the latter of which is not relevant to this case. Inference is particularly important in a Chinese-majority society. Chinese families, particularly those involving older generations, are reluctant in discussing money matters including the division of proprietary interests. This is acknowledged in Primecredit[12] by Vice President Lam (as he then was)[13] and Cheung J.A.[14] The judge therefore erred in (1).


In sole legal owner cases, including the current case, such inference must be supported by proof of detriment. In English jurisprudence, lower courts are bound to find that nothing less than financial contribution to the purchase can be used in establishing the inference.[15] Stack v Dowden is technically obiter in these cases. However, this issue does not arise in Hong Kong jurisprudence. The HKCA in Primecredit applied Stack to sole legal owner cases as well. Although the judge in this case was correct to state that marriage alone could not establish beneficial ownership, they erred in holding that only direct financial contributions mattered.


Further and alternatively, even if the judge followed English jurisprudence (which they were not entitled to do, given that there was binding Hong Kong authority), they still reached the wrong conclusions on (2).


The holistic approach in Stack v Dowden originated from the observation that English law moved to keep up with overall socioeconomic changes.[16] This is reinforced by recent appellate decisions.[17] Furthermore, concerning sole legal owner cases, Oxley v Hiscock (decided after Lloyds Bank v Rosset- a Court of Appeal decision) held that a holistic approach should be used.[18] Although it contradicted Rosset, it was endorsed in Stack v Dowden.[19] Stare decisis was therefore observed.


In England and Wales, this development coincides with the abolition of the presumption of advancement concerning resulting trusts.[20] This renders the law more relevant to a community founded on gender equality. Societal differences between England and Hong Kong, including opinions on gender equality, are not significant to justify any departure from this reasoning. Hong Kong enacted the Sex Discrimination Ordinance (Cap. 480) in 1996, parallel to relevant provisions in the Equality Act 2010 in England and Wales.


Thirdly, in light of Lloyds Bank v Rosset, Lord Bridge’s determination that nothing less than financial contributions could be used for inferring a common intention is prefaced by ‘as I read the authorities’. It is reasonable that the court felt bound by pre-1991 authorities to come to such a conclusion. However, after Stack v Dowden, and reinforcement of the dicta therein by subsequent authorities by Supreme Court justices,[21] Rosset should no longer be relevant.

Ground 2: Transfer/Sale of Equity of Redemption

The judge concluded, in [41], that even if Ms Chan could establish a beneficial interest in the property, she would not be able to exercise any equity of redemption. As the Trustees owed due diligence to other creditors, when deciding whether the equity should be transferred to Ms Chan, the interests of other creditors should be heeded first. The judge held that, since there was no evidence that Ms Chan had sufficient funds to redeem the mortgage, she should not be transferred the equity.


This argument is fallacious.


Mr Lee had held the Property on trust in favour of himself and Ms Chan. Since the mortgage was a liability attached to the Property,[22] and the equity of redemption arose in response to the mortgage,[23] the equity could be deemed an integral part of the same trust. This appeals to the fund concept of trusts proposed by Penner and Chambers.[24] As Mr Lee was declared insolvent, the Trustees stepped in his shoes (metaphorically). This does not affect the magnitude and scope of Ms Chan’s pre-existing interest, nor Mr Lee’s obligations owed to Ms Chan under the trust. Per Lord Justice Millett in Armitage v Nurse,[25] the distinguishing, essential feature of a trust is that the trustee must act on behalf of the best interests of the beneficiary. The Trustees must therefore exercise the equity of redemption to advocate for Ms Chan’s best interests. This should entail exercising the equity to protect Ms Chan’s right from extinguishment by foreclosure.


Furthermore, this interest is proprietary in nature. It would be independent of Mr Lee’s asset pot available for distribution amongst his creditors.[26] When exercising the equity of redemption, it is therefore against authority that the Trustees be required to consider the interests of all creditors before deciding whether to exercise the equity.


Submissions from the Trustees in [27] of the judgment that Ms Chan could only intervene should the Trustees improperly exercise the equity did not alter this conclusion. Trusteeship entails a bundle of duties. Trustees cannot simply pick and choose.


Alternatively, the equity of redemption is held on a bare trust which is concurrent to the common intention constructive trust imposed on the Property.


According to Saunders v Vautier,[27] the beneficiary acquired the legal ownership of the asset(s) from the trustee when they reached the age of maturity, four years in advance of the anticipated date of receipt. This arrangement is particularly attractive when making bequests in olden times. However, this example is merely indicative, not exhaustive. In a bare trust, the beneficiary shall be treated as a quasi-legal owner (if not entirely) until the point of acquisition of full legal interest. The trustee is tantamount to a custodian here, i.e. keeping the property until the beneficiary is ready. Equality underlies this arrangement.


The bare trust concept should be used in situations analogous to this case.[28] Primecredit is testimony to the courts’ view that matrimonial assets form part of a common venture between two partners.[29] Although one party (‘Party X’) is often appointed to implement the procedures of the venture (as in this case), it does not suggest the parties (‘Parties X and Y’) are unequal. Indeed, it evinces an even stronger intention of collaboration since there is a division of obligations. Equality underlies the common venture.


Party X acts in two capacities: (1) an agent for Party Y; and (2) an agent for themselves. Hence, regarding the equity of redemption, since it is the key to the success of the joint venture, it is intended that both parties have an equal say on how and whether it should be exercised. This accords with the guiding principle of bare trusts.


This proposition is an extension of traditional juridical principles governing the equity of redemption. According to Pawlett v Attorney General,[30] the equity is a right ‘inherent in the land’ which is ‘assignable and devisable’. It is not subsidiary to other interests in the property, such as the legal estate of the mortgagor.[31] It could therefore be held on trust. The trust arrangement can also assume a different morphology to that which binds other interests, i.e. the legal estate here. This is supported by academic authority, notably Cousins.[32] There is no evidence that this analysis was restricted by the provisions contained within the mortgage contract here.


If the bare trust analysis were accepted, Ms Chan would acquire the legal ownership to the equity upon the occurrence of an event which threatens the husband’s role as trustee, whereby the viability of the joint venture is impugned, i.e. equality could no longer be maintained. Insolvency is such an event. Ms Chan could therefore exercise the equity to redeem the mortgage.


In addition, it is unreasonable to encumber the exercise of the equity with an arbitrary threshold: that Ms Chan is capable of paying off the mortgage debt.[33]  Deciding otherwise would allow a third party (the Trustees in this case) to take the reins of the equity. Ms Chan’s index consent to entering the joint venture would be impugned since her rights attached to the equity are unjustifiably curtailed. This is against what has been decided in Primecredit and Mo Ying.


Further, the judge’s analysis risks unjustly enriching the Bank at Ms Chan’s expense. The purpose of the equity of redemption is the careful calibration of interests between the mortgagor and mortgagee. Since the Bank’s interest takes precedence over Ms Chan’s, without her involvement in the exercise of the equity, her beneficial interest in the Property is potentially extinguished upon foreclosure.


The Trustees, holding the equity, were very unlikely to exercise it. They could only exercise the power with the permission of the creditors’ committee.[34] The creditors’ committee was unlikely to approve this, given their interest in getting as many assets included in the distribution pot as possible. The Bank would benefit from having its legal charge ‘upgraded’ to legal ownership in practical terms. This is unjust owing to a want of authority.[35]


Ground 3: Errors in Fact-Finding

The judge might have omitted the consideration of some relevant factors when determining whether a common intention constructive trust could arise from the factual matrix.[36] These factors were not discussed in the HKDC judgment. However, for the sake of brevity, only the provenance and application of the $200,000 borrowed by the second defendant will be discussed here.


Ms Chan borrowed HK$200,000 from her brother-in-law to fund the purchase.[37] The judge dismissed this as irrelevant since it had been returned to the husband. Any associated fees regarding the purchase were successfully covered by the mortgage and government loan.[38]


This should be rejected due to the following reasons:


a)     It is unknown whether the judge considered if the sum was paid towards any instalments;


b)     Mr Lee might have used the sum to satisfy his debt obligations owed to the government. Since Mr Lee took out a government loan, deductions might be made from his monthly income and retirement fund. Such deductions might originally have been set aside for Ms Chan since, given she was a housewife, it was her husband’s custom to make monthly maintenance payments to her. This implies the possibility that Ms Chan financially contributed to the acquisition of the Property.


c)     Mr Lee’s bank account, where the $200,000 was deposited, might have been overdrawn at the time any possible dispositions were made to satisfy any debt obligations. Even if it were overdrawn, backward tracing is increasingly accepted in the common law world,[39] in light of the increasing complexity of commercial transactions. The judge should have considered this possibility.


Part III. The HKCA Judgment and its Impact

The HKCA allowed Ms Chan’s appeal on both issues. There is a separate issue regarding whether the Bank unjustifiably obstructed Ms Chan from redeeming the mortgage, thereby leading to cost implications. This lies outside the ambit of this article.


Concerning the common intention constructive trust, it stated that:


…direct financial contribution to the acquisition of the property is not the only relevant consideration, particularly in the domestic context. A proper consideration of whether a common intention constructive trust exists would require a careful, objective, consideration of the whole course of conduct of the parties.[40]


The panel declined to analyse the full merits of Ms Chan’s common intention constructive trust claim since a full trial was considered to be a superior forum for its adjudication.


Concerning the equity of redemption issue, it stated in [32] of the judgment that:


(1)   … if the 2nd Defendant [Ms Chan] is a beneficial owner of the Property, she is entitled to exercise her right to redeem the Mortgage, and does not require the Trustees to transfer or sell such right to her.

(2)   …We see no reason in principle why a beneficial owner may not exercise the right of redemption in the absence of consent from the other co-owner/mortgagor (or his successor in title) or the trustee of the beneficial owner, at any rate where their interests do not align.

(3)   on the footing that the 1st and 2nd Defendants [both Mr Lee and Ms Chan] are both beneficial owners of the Property, it is by no means clear that the Trustees’ wish to sell the Property under the Partition Ordinance would necessarily prevail over the objection of the 2nd Defendant…[the Court refused to lay down a definitive statement on this point]

(4)   …there was no reason why the 2nd Defendant should be required to pay off the 1st Defendant’s general body of creditors, or purchase the 1st Defendant’s interest in the Property, before she could exercise the right to redeem the Mortgage…

(5)   … the Judge seems to have thought, mistakenly, that the 2nd Defendant was seeking to require the Trustees to transfer the right of redemption to her. In fact, she was seeking to exercise her own right to redeem the Mortgage.


Some may suggest that all is right in the end. The HKCA corrected the narrative and eradicated the roots of an emerging error. There is nothing else to fear. However, both realists and nihilists alike concur that there are commercial reasons behind the judge’s decision.


Hong Kong is an international financial centre. It has long been deemed an offshore jurisdiction, providing numerous benefits for those who wish to conduct business activities there.[41] This commercial focus helps bolster Hong Kong’s reputation in the region. For instance, Hong Kong recorded the highest number of arbitrations in 2022 since 2010, with a 24.2% increase from 2021. Furthermore, the vast majority of disputes submitted to Hong Kong’s jurisdiction were international in nature, i.e. 83.1%, in 2022.[42] Commerciality is therefore an ingrained societal notion that affects the general development of Hong Kong law.


One advantage of the HKDC judgment is maintaining the stability of the mortgage market. If the law over-emphasises spousal interests in cases involving banks, banks may be less willing to enter into mortgage agreements with families. Alternatively, they may increase interest rates, run more stringent financial assessments before approval, or raise the threshold of approval. Hong Kong is one of the most expensive property markets in the world.[43] Most residents could only afford a property with a mortgage. Potential changes in mortgage requirements may further decrease property ownership rates and exacerbate pertinent issues such as homelessness. Further, if banks are not given sufficient incentive to operate in Hong Kong, their departure might tarnish Hong Kong’s reputation as a business hub in the Asia-Pacific region.


Moreover, it is doubtful whether the HKCA indeed resolved the issue. Legal academia and practice vary in their objectives. The former seeks to unearth the truth and focuses on doctrinal neatness. The latter places a greater emphasis on practical considerations such as social policy. The HKCA judgment made assertions which lacked doctrinal exploration. It was stated that Ms Chan held a right to redeem the mortgage. This was linked to her potential beneficial interest in the Property. But why? The equity of redemption is arguably a separate interest from the legal estate. What is the linkage therein? Why and how can an interest in one translate into an interest in another? The absence of doctrinal reasoning renders it difficult for the lower courts to follow. In more nuanced cases, the lower courts are less likely to seek guidance from doctrinal principles to ensure coherence with current law. Commercial considerations might be inadvertently prioritised in family cases, making bad law.


This is a significant issue. Returning to the real world from the malaise-inducing academic building, very few people contemplate litigation due to the potential costs of legal representation. Even fewer would pursue an appeal. If the line of reasoning adopted by the HKDC were extended to analogous cases, absent further instruction from the HKCA, it would be doubtful whether the rights of families could be adequately protected.

Whether this is only secondary to commercial interests in Hong Kong society remains an open-ended question. Whether this, if true, is a genuine ‘error’ depends on one’s perspective. After all, society and the law evolve in lockstep.


Nonetheless, certain universal norms unite societies. Examples include respect for human dignity and individual autonomy. These norms are explored in-depth by jurisprudential scholars such as John Rawls and Immanuel Kant. They need no recitation here. Respecting familial interests, especially the right to keep the family home, appeals to fundamental human rights.


Part IV. Conclusion


How a court adjudicates matrimonial cases reflects what a society thinks about their families.


Although Hong Kong is a more commercially focused society, there is still ample room for love, altruism and harmony. Indeed, there is a phrase which is commonly used in Cantonese conversation: ‘人情’ (literally translated as ‘being humane’, although one might argue that there is no true English equivalent).


Commercial considerations are important. A city’s reputation is important. However, do they matter much if the law cannot even protect the right of a woman, who has diligently supported her family for decades, to remain in her home?



*Alexander Clevewood Ng is the Deputy Editor-in-Chief of the City Law Review. He had been an Editor of the UCL Journal of Law and Jurisprudence. He graduated from UCL Laws and is a current Bar Course student at City, University of London. He undertook a mini-pupillage at Temple Chambers, a leading set of barristers’ chambers based in Hong Kong.

[1] Pettkus v Becker [1980] 2 SCR 834.

[2] Shanghai Commercial Bank v Lee Yau Tak [2021] HKDC 69.

[3] Stack v Dowden [2007] 2 AC 432, [54]. This presumption is adopted in Hong Kong law as well.

[4] [2017] 4 HKLRD 327. Another instructive authority is Mo Ying v Brillex Development Ltd [2015] 2 HKLRD 985.

[5] n.3.

[6] This operates on the presumption that the equity of redemption is not extinguished but rests in the hands of the Trustee(s). This presumption is not challenged in the District Court judgment.

[7] [1991] 1 AC 56.

[8] n.2, [14]-[18].

[9] n.2.

[10] n.3.

[11] Id, [68]-[69].

[12] n.4, [1.6] and [2.9].

[13] He is currently sitting as a Permanent Judge in the Hong Kong Court of Final Appeal.

[14] J.A. refers to Justice of Appeal of the HKCA.

[15] Lloyds Bank v Rosset, [1991] 1 AC 107, 132-133.

[16] n.3, [60].

[17] Marr v Collie [2017] UKPC 17, [54]-[55].

[18] [2004] EWCA 546.

[19] n.3, [61].

[20] Equality Act 2010, s.199.

[21] e.g. Jones v Kernott [2011] UKSC 53.

[22] Ambrister v Lightbourn [2012] UKPC 40.

[23] Kreglinger v New Patagonia Meat and Cold Storage Ltd [1914] AC 25, 48.

[24] Penner and Chambers, ‘Ignorance’ in Degeling and Edelman (Eds) ‘Unjust Enrichment in Commercial Law’ (Lawbook Co., 2008), 268-271.

[25] [1997] EWCA Civ 1279, [253].

[26] Re Lehman Brothers International (Europe) (in administration) [2009] EWCA Civ 1161, [33].

[27] [1841] EWHC J82. This is recognised in Hong Kong jurisprudence, e.g. see Hotung v Ho Yuen Ki (2002) 5 ITELR 556.

[28] Pearce v Morris (1869) 5 Ch App 227, relied upon by both the judge and counsel for the trustees in bankruptcy, only details the role of the mortgagee in conveying title deeds to a party which (1) has the equity of redemption, and (2) exercises said equity. It is no authority for the proposition that, in any case, the trustee necessarily holds the primary right to exercise the equity.

[29] n.4.

[30] (1667) Hard 465, 469.

[31] Clark, ‘Fisher and Lightwood’s Law of Mortgage’ (15th ed), 998.

[32] ‘Ch28: The Equity of Redemption as an Interest in Property’, Cousins, Clarke and Hornett (Eds) ‘Cousins on the Law of Mortgages’ (4th Ed) (Sweet & Maxwell, 2017), 588.

[33] The judge’s conclusions appear to be influenced by the Family Law Act 1996, s.30(3) enacted in the United Kingdom, and Hastings and Thanet Building Society v Goddard [1970] 1 WLR 1544. However, even if there were a parallel Act in Hong Kong with the exact wording, such an assertion would be unreasonable. According to s.30(1) of the same Act, the section only applies if only one of the spouses is not entitled to the matrimonial property. As explained in Ground 1, the second defendant is a beneficial owner of the Property. This therefore takes the matter outside the ambit of the section.

[34] Cl.61(h), Bankruptcy Ordinance (Cap. 6). The equity of redemption was not Mr Lee’s property since he held it for the benefit of himself and Ms Chan. It should therefore lie outside the power of disposition of the Trustees. However, the wording of Cl.61(h) is wide enough to encompass any arrangement ‘incidental to the property of the bankrupt’. The equity of redemption reasonably falls within its ambit. Therefore, approval by the creditors’ committee is likely required.

[35] See, for instance, Lipkin Gorman v Karpnale [1988] UKHL 12, and Trustee of FC Jones and Son (a firm) v Jones [1996] EWCA Civ 1324. Although ‘want of authority’ is not explicitly named the unjust factor in these cases, it sensibly serves as a common thread. This analysis is supported in Goff & Jones The Law of Unjust Enrichment (10th ed.).

[36] Following the principles laid out in BMC v BGC [2020] HKCA 317. The judge conducted an unreasonable evaluation of primary facts, having: (1) misapprehended the facts; (2) failed to take into account relevant matters, i.e. factors other than financial contributions which lead to the inference of common intention; and as a result (3) came to a conclusion lying ‘outside the ambit within which a reasonable disagreement is possible’. These limbs are outlined in BMC v BGC, [82]-[86].

[37] n.2, [11](2).

[38] Id, [31].

[39] Brazil v Durant [2015] UKPC 35; Relfo v Varsani [2014] EWCA Civ 360.

[40] Shanghai Commercial Bank v Lee Yau Tak [2023] HKCA 450.

[41] ‘A Challenge to Hong Kong’s Long-Established Offshore Tax System’ (Deloitte, 25 October 2022) <> accessed 12 February 2024.

[42] Lianjun Li and others, ‘HKIAC Records 12-Year-High Number of New Cases’ (Reed Smith, 3 February 2023) <> accessed 12 February 2024.

[43] Kate Everett-Allen, ‘How Much Property Will $US1 Million Buy You across the World?’ (Knight Frank, 1 March 2023) <> accessed 12 February 2024.

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