14/08/2026
14Aug2026 - Rethinking 99-1 deals
Three key lessons emerge from the Court of Appeal’s decision:
(1) legal ownership and beneficial ownership are not always identical;
(2) the parties’ intentions at the time of acquisition are critical; and
(3) ownership structures adopted to facilitate the evasion of stamp duty or ABSD may be tainted by illegality, potentially rendering trust claims arising from those arrangements unenforceable.
The recent decision of the Court of Appeal of Singapore in WMLM v NSRJ [2026] SGCA 27 is one of the most significant property law judgments concerning 99:1 ownership structures, resulting trusts, and beneficial ownership of residential property. The judgment provides important guidance for purchaser...