Supreme Administrative Court ruled no transfer tax applies to water usage rights separate from land lease rights.

The Supreme Administrative Court held that no transfer tax was due when water usage rights were transferred separately from land lease rights. The applicant argued that these distinct rights should be treated as separate transactions under the Transfer Tax Act, while the tax authority claimed they constituted a single transfer. The court decided that since the water usage right is not part of the land lease right, it falls outside the scope of the transfer tax provision.