The Art Law Review: Recent Developments in the Art Market

The art market triumphed in its fight for survival in 2021. At the close of 2020, the UK market was gearing up to face the threatening triad of Brexit, greater regulatory oversight and the persistent economic damage from the pandemic. Although these challenges are not behind us, the market's rise against the odds this year is a testament to the resilient and innovative forces that fuel the creative industries. Every part of the market seems to be setting the pace for what will be the new normal, no longer just hoping for a return to a pre-pandemic familiar rhythm. As 2021 came to a close, there was not only a glimmer of light but room for excitement and optimism. Although emotions are mixed for many as challenges persist, this feeling seems to pervade the industry. According to a survey carried out by ArtTactic, overall confidence in the art market has reached its highest point since 2014 at 80.6 per cent, up from an all-time low in May 2020.2

Experts expected 2021 to be a year of rehabilitation rather than rip-roaring recovery. However, the market both in the UK and abroad has surprised even itself with impressive figures. In the first half of 2021, auction sales were up 230 per cent compared to the first half of 2020.3 Sales at Sotheby's, Christie's and Phillips totalled US$5.9 billion by 30 June 2021, up from US$1.75 billion for the same period in 2020.4 Galleries, too, have reported that the numbers they achieved exceeded their expectations by beating pre-pandemic figures.5 Some of the most energetic forces behind this positive outlook were undoubtedly digital innovation and the rise of a young generation of collectors.

2021's year's growing wave of confidence, innovation and recovery is not oblivious to the issues that remain. The implications of Brexit, while they have slowly crystallised from a legal perspective, have not yet been fully felt from an economic one, and 2021 has been a year ripe for London to take stock of its rival markets, both familiar and emerging. The UK government has had to thread carefully in adjusting the structure of the market's regulatory framework following Brexit. Adapting to anti-money laundering regulations has been challenging and costly for businesses across the UK and the same challenge is around the corner for the market on the other side of the Atlantic.

2021 was also the year in which the online world gained the market's trust. The opportunities and challenges presented by digital innovation had been on the market's agenda before the pandemic. Digital innovation had been making its way up the art market's layers for years, but it had been slow to reach the top end. After 2020 accelerated a reluctant shift, trust in online transactions grew in 2021. Although buyers were slow to brave online platforms and online viewing rooms for the purchase of higher end works, the average lot value this year, for example, was US$27,000. This is a twofold expansion from 2020, and six times the average value of 2015.6 Overall online sales continued to rise in 2021, up 178 per cent on the same period in 2020 to £158.8 million.7 Proof that the digital world is not here to eradicate but complement traditional platforms, auction houses have reported that private sales, too, have been booming. They accounted for 25 per cent of Christie's sales in the first half of 2021.8 Crime control organisations are also not letting the digital shift go to waste as evidenced by Interpol, which this year created an app to reinforce its efforts to eradicate art trafficking.9

Then came non-fungible tokens (NFTs), the art world's formidable growing pain. Blockchain technology has existed since 2008, yet Beeple's record-breaking £50 million NFT sale of Everydays: The First 5000 Days in March was a bombshell for many.10 Since then, NFT sales have risen fast and steeply as some warned, while others hoped that the bubble would burst.11 While speculative buyers flocked to embrace the investment opportunity, many blue-chip collectors stayed away, wondering whether the exclusivity inherent to owning a work no one else could see had become antiquated overnight. At the time of writing, the dust seems to have settled and the NFT market is still alive and well. Bitcoin technology is slowly freeing itself of the scepticism it inspired within parts of the art market. It has both attracted core market actors such as top-end auction houses and in turn introduced the market to its newest participants – a new young and tech-savvy generation of millennial collectors whose demand for both NFTs and other categories of works carried several sectors of the industry through the pandemic. Per the latest Art Basel annual report, high-net-worth collectors were the highest spenders in 2020, with 30 per cent having spent over US$1 million (versus 17 per cent of Boomers), and figures this year indicate that the numbers are unlikely to fall.12

As we tried to decipher the new phenomenon that entered without knocking, this year reminded us that the development of digital art forms far precedes 2021. With it had come the possibility to reproduce a work endlessly without affecting its quality. Original digital works were thus condemned to the risk of gradually losing appeal and value. Crypto art is a new category of digital art that seeks to address this issue by using blockchain technology. The latter can incorporate the artistic medium by affixing it to unique NFTs on a blockchain (the process referred to as 'minting'). While NFTs cannot prevent the unauthorised reproduction of a minted artwork, an NFT itself cannot be duplicated, giving it a cachet akin to 'originality'. Enthusiasts were, however, reminded that the promised guarantee of authenticity offered by minting an NFT is only as good as the authenticity of the artwork that is attached to the NFT.13 An equally important warning is the fact that the life of a digital work saved on an NFT may be finite. An NFT remains only a link to the media content tied to it (the digital artwork itself). The latter is often saved on the server of a website run by the seller that markets it. This makes the NFT a house of cards for the artwork if the seller, often a start-up, goes out of business and takes the content of the NFT with it.14

In addition to a new category of art and collectors, NFTs also introduced the market to innovative means of transacting. Although it was long predicted that the tokenisation of physical works of art would fail,15 this year proved that blockchain technology can and did attract the traditional physical realms of the art world with unexpected cross-breeds such as 'NFT twins' of a seventeenth-century Delftware vase created using 3D technology.16 Christie's and Sotheby's have both curated dedicated NFT sales and the latter accepted cryptocurrencies as payment for physical works of art for the first time this year.17 Tokenisation is also becoming a popular means of provenance control because all NFT purchases are recorded on the blockchain. Commissions, too, can be attached to NFTs through which the author is paid a form of resale right when the work is resold on the secondary market, akin to a form of automated artist's resale right. Discrepancies, however, exist in the way NFTs are minted and smart contracts are used across platforms. This impacts artists' ability to market their works if, as is often the case, smart contracts differ across platforms. Professionals in the tech, art and legal fields are increasingly joining forces to solve the conundrums that plague the medium.

Still, this gives the legislator a lot to catch up with. Digital files can be created in incalculable amounts, and NFTs enable cross-border transactions at unprecedented speed and in large volumes. Discrepancies in national laws expose those who rely on blockchain technology to conduct business to ambiguous legal issues. Anti-money laundering frameworks, too, remain ill-equipped to regulate these transactions, which hinders the disclosure of identity. Cryptocurrencies in turn make it difficult to determine whether a given transaction meets the compliance threshold. Finally, best copyright and moral rights practices have yet to be developed. This was evidenced by the withdrawal of an NFT of a drawing by Jean-Michel Basquiat because the seller owned no copyright licence to reproduce the work.18 The burning of a work by Banksy filmed and minted on an NFT, despite the Banksy-esque theatricality it pursued, also raised important questions about the artist's moral rights.

There remain, as always, questions that may never be answered. Sales of NFTs such as the early time-stamped copy of the source code of Sir Tim Berners-Lee's invention of the world wide web, which sold for US$5.4 million at Sotheby's in June 2021, renew the promise that the evergreen question 'what is art?' is unlikely to be exhaustively answered. The next chapter promises to be interesting as the NFT boom is reportedly now marching on to conquer the fashion industry.19

2021 was a key year for London to take stock of its competitor markets and evaluate the opportunities and risks inherent in the regulatory reforms both imposed and made possible by Brexit. It has perhaps rarely been more important for the UK to critically evaluate what is key to its reputation as a leading market. While the US, the UK and Greater China continue to dominate the global market share with an aggregate hold of 82 per cent,20 regulatory shifts may tip the scales and formerly discrete rivals are gaining strength.

In the first edition of The Art Law Review, we warned that increased anti-money laundering regulation may have a disproportionate impact on the London art market due to its focus on a dazzling variety of international clients and high-value transactions that give rise to circumstances requiring enhanced due diligence. It was difficult to predict, in the then US political climate, whether equivalent regulatory changes would reach the other side of the Atlantic. The US Senate report published in July 2020 that revealed sanction evasion by Arkady and Boris Rotenberg had put the art market more firmly on the regulator's radar. Experts warned of the pitfalls of relying on popular tropes of the art market as a forum rife with crime and the need to take an informed and evidence-based approach to regulatory reform. Since then, the US Congress passed the Anti-Money Laundering Act 2020, which expands the definition of financial institutions under the Bank Secrecy Act 1970 to include 'dealers in antiquities'.21 The definition is more expansive than it may appear at first sight as it includes advisers, consultants and any other person who engages as a business in the solicitation or the sale of antiquities. These businesses are required to conduct anti-money laundering checks, register the ultimate beneficial ownership of limited liability companies and report suspicious activity. Though still less far-reaching than EU regulations, these changes confirm that federal policymakers have the art market in their sight.

Much will be determined by how the UK adapts to its own regulatory shift. The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 came into force in January 2020 to implement the EU's Fifth Anti-Money Laundering Directive.22 Qualifying art market participants (AMPs) such as dealers, agents, auction houses and freeport operators have since grappled with the obligations to develop internal anti-money laundering policies, carry out risk assessments of their businesses and train their staff as the registration deadline approached. While this has not been entirely easy for the handful of market actors with large and experienced compliance teams, it has been even more difficult for galleries and dealers, which make up more than half of the market. Artists breathed a sigh of relief when the UK Treasury made a very last-minute decision days prior to the deadline for registration that creators who sell their work direct to clients will not be classed as AMPs.

One of the most difficult aspects of compliance remains the challenge posed to the market's core value of confidentiality. The business of most AMPs depends on their ability to protect their contact lists from competitors and guarantee discretion to their clients. Customer due diligence and the disclosure of clients' identities, although undeniably paramount to combating money laundering, have left some AMPs struggling to balance compliance with commercial sensitivity.

The first detailed guidance document to assist AMPs in ensuring compliance was published by Her Majesty's Revenue and Customs (HMRC) and the British Art Market Federation in January 2020, followed in June 2021 by another guide on understanding money laundering risks. While welcomed by the trade, these documents are complex to navigate and leave critical questions unanswered. The first guidance document led to a widespread misunderstanding of the notion of 'reliance', whereby an AMP is permitted to rely on a third party's customer due diligence provided certain conditions are met. Some AMPs had misunderstood the notion, misled by the lack of clarity in the guidance and the hope that it could allow them to avoid the disclosure of sensitive client information. The guidance documents also do little to clarify the ambiguity that remains regarding the definition of works of art under the Regulations. The definition, adopted from the VAT Act, excludes antiques and collectibles but leaves the definition of the latter open to unpredictable and highly subjective interpretation. It also remains unclear how and on whom client due diligence checks should be carried out where a transaction involves a chain of intermediaries, as happens daily in the art market.

The lack of clarity that persists nearly a year and a half since the Regulations came into effect is problematic. AMPs are still too often faced with questions they cannot answer on how to ensure compliance in given situations, a difficult burden to bear under the threat of serious civil and criminal penalties. At the time of writing, the government is considering stakeholder feedback on amendments to the Money Laundering and Terrorist Financing (Amendment) Regulations 2019. The industry's views were gathered during a public consultation, which ran from July to October 2021. Under current plans, changes will be implemented through focused secondary legislation due to be laid in spring 2022. The amendments intend to ensure that the UK continues to meet international standards set by the Financial Action Task Force, while also strengthening and ensuring clarity on how the anti-money laundering regime operates following feedback from industry, stakeholders and supervisors on the implementation of the Money Laundering and Terrorist Financing (Amendment) (EU Exit) Regulations 2020.

Continental markets are embracing new opportunities to compete with London. When we wrote this chapter last year, the opportunity for the historic competition between Paris and London was revived as the uncertainties of Brexit loomed and global galleries tentatively expanded to Paris. Millions of pounds' worth of artworks were being rushed out of the UK before the Brexit cut-off date,23 and the market was largely in the dark about the content of the trade deal or indeed whether one would be reached at all. The regulatory implications of Brexit have slowly begun to crystallise since. The benefits and disadvantages of these developments for the UK market are highly nuanced and many are conditional upon the next steps taken by the government. While certain regulatory changes, such as changes to the VAT regime, will affect the market in straightforward ways, quiet repeals leading to lower restrictions carry evolving risks for the reputation of the market and no guarantee to benefit the trade. It is essential for the government to ensure that these changes are accompanied by the effective enforcement of existing regulations and address emerging regulatory inconsistencies with EU law.

Import VAT is one of the largely anticipated changes resulting from Brexit. This is now payable when importing works of art, antiques and collectibles into Great Britain (but not Northern Ireland) from the EU (at 5 per cent) and into the EU from Great Britain (for example, at 7 per cent in Germany, at 5.5 per cent in France and at 9 per cent in the Netherlands). As we noted in the first edition of The Art Law Review, a Brexit-related loss is the UK's former status as a gateway into the European market resulting from its attractive low import tax rate. Now that the UK is treated as a third country, this advantage is lost. Purchasing works under the margin scheme from sellers located in EU Member States is also no longer possible as they will now be considered exports from the EU. To divert these imports into margin scheme stock, importers will have to opt not to recover the import VAT payable on the import by notifying HMRC. The temporary admissions procedure, however, still exists and continues to allow works of art to be temporarily imported for exhibitions and art fairs. Bonded warehouses are also still in operation, so works can be held in storage without duties or taxes being paid upfront. The government has also announced the construction of eight new freeports, which could boost the UK's status as an international entrepôt. Whether these new freeports will benefit the UK art market will depend on whether the government opens them up to the storage of high-value goods such as art (that is not the intention at the time of writing) and if it does, whether it puts effective measures in place to prevent tax evasion and money laundering to minimise the risk that freeports are used as safe storage for illegally trafficked art and cultural property.

Another change that will determine the reputation of the UK art market in the years to come is the government's decision to repeal the EU Cultural Goods Import Regulation,24 originally retained under the terms of the EU (Withdrawal) Agreement Act 2018. The Regulation is complex and was much criticised by the art market during consultations, principally for its breadth and lack of detail. It introduces an import licensing system, sets the framework for a digital database expected to be operational by 2025, and applies to cultural goods exported in breach of the laws and regulations of their country of origin by prohibiting their import into the EU. While resistance to the Regulation is understandable, as the UK Committee for the Blue Shield has warned,25 its repeal risks damaging the UK's reputation if not accompanied by concerted efforts to enforce existing rules and controls more appropriately at borders and address the growing inconsistencies between the EU and UK systems. This will be essential to prevent creating the undesirable impression that Great Britain is a natural destination for objects that do not meet standards implemented across the EU. An added complication is that the Regulation will apply in Northern Ireland as part of the Northern Ireland Protocol even if it will not in Great Britain. As a result, authorities in the UK will have to continue supporting Northern Ireland in its enforcement of the Regulation. The import controls currently implemented by the UK are insufficient to meet the Regulation's objectives – if the government does not alter its approach insofar as controls on objects entering Northern Ireland's jurisdiction are concerned, Northern Ireland risks being in breach of the Regulation.26 It is now essential for the reputation of the UK art market that the government invests in ensuring that adequate guidelines are produced and that risk assessments and training of customs officials are carried out to preserve the UK's status as an international entrepôt and trade destination for the legitimate art market.

Some European countries have carefully loosened their export rules in an effort to gain a competitive advantage in the trade. This year, the French government has finalised plans to reform its Cultural Heritage Code by increasing the value threshold below which a variety of works of art and cultural property more than 50 years old will no longer require an export licence to leave the country. Italy, too, is reforming its export laws to reduce red tape. A reform that came into effect in 2020 for the benefit of the lower end market permits the export of works of living artists or those who died less than 70 years ago (previously 50 years). Older art and antiques require an export licence only if they are valued above €13,500. In the UK, art, antiques and collectables that are more than 50 years old and exceed a certain value require an individual licence for export out of the country from the Export Licensing Unit of the Arts Council England. EU export licences no longer apply; however, the Arts Council is introducing an online system, expected to go live this autumn and simplify the application process.27

Following Brexit, the UK's options to recover cultural property that was illegally exported but not stolen, are now more limited. Prior to Brexit, the UK had implemented the 2014 EU Directive on the return of cultural objects unlawfully removed from the territory of a Member State.28 Under the Withdrawal Agreement,29 two legislative instruments revoked the UK 2015 Implementing Regulations of that EU Directive. The EU–UK Trade and Cooperation Agreement (TCA) now provides that the EU and the UK will continue to cooperate in facilitating the return of cultural property illicitly removed from their respective territories in accordance with the 1970 UNESCO Convention.30 The TCA maintains the mutual cooperation obligations derived from the 2014 Directive, which require parties to notify each other when cultural property is found in their territory and whether there are reasonable grounds for believing the property was illicitly removed from the territory of the other party. The TCA does not, however, maintain the UK's right of action in the courts of EU Member States to recover the cultural property and the reciprocal rights for EU Member States. There is room to argue that the UK would benefit from ratifying the 1995 UNIDROIT Convention on Stolen or Illegally Exported Cultural Objects, especially because it does not have bilateral treaties with other countries designed to facilitate the return of illegally exported property.

Regulatory shifts are also key to the UK's reputation as a global capital of creativity rich with talented artists, both emerging and established, that nurture its market for contemporary art. An important development and a relief for artists was the confirmation given by the government that no changes were planned to the artist's resale right (ARR). The trade deal includes clauses relating to the resale levy whereby both the EU and UK have committed to continuing to enforce the ARR as part of the level playing field. Brexit has also provided some yet-to-be seized opportunities to repeal inadequate EU regulations such as those affecting the application of VAT and customs duties to neon art and video installations. The UK is no longer obliged to follow Commission Regulation (EU) No. 731/2010, which prescribes the antiquated classification (and subsequent higher taxation) of video and light installations as electrical or video equipment rather than as works of art.31 This instrument, which was drafted to overturn the widely supported position taken by the English courts in Haunch of Venison Partners Ltd v. HMRC32 that neon and video installation works can and should be classified under Chapter 97 of the Combined Nomenclature (as 'original sculptures and statuary, in any material'),33 is ripe for deletion from the statute book. This could only contribute to affirming the UK's status as a hub for innovation and creativity.

It also remains to be seen whether the UK's strict restrictions introduced by the Ivory Act 2018 will set the market at a disadvantage compared to continental jurisdictions. While the government has confirmed that it is working towards implementing the Ivory Act by the end of 2021, the European Commission published a draft regulation and guidance in January 2021 to ban the EU trade in ivory. The effect of the new measures is to simplify and strengthen the current rules while permitting only limited exceptions. Both instruments were open for final public feedback. Regardless of Brexit, the draft EU regulations will impact not only trade between EU Member States but also between Member States and the UK. The UK may, however, remain a step ahead in its strict regulatory restrictions considering the consultation that was launched to extend the Ivory Act to other non-elephant ivory-bearing species. Although there was little doubt in this regard, it is now also firmly confirmed that the UK remains a party to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). The EU Wildlife Trade Regulations,34 which were in force in the UK before Brexit, will continue to apply in the UK as retained EU legislation, albeit in an amended form. CITES-designated points of entry and exit must be used to move CITES specimens between Great Britain and the EU.

When moving CITES specimens from Great Britain to Northern Ireland or vice versa, the import and export checks will take place in Northern Ireland. For all CITES species that enter the UK from outside the EU, different animal and plant health conditions apply.35

Continental rivals aside, rising markets deserving of special attention are those emerging across Asia where demand from an enthusiastic young generation of buyers is fuelling the growth of new markets. Asian buyers have now become the dominant force at the top end of the auction market, according to Christie's,36 which announced plans to open a permanent salesroom in Hong Kong this year.37 Greater China continues to claim a 20 per cent share of the global art market, owing to sales to mainland collectors and those in Hong Kong where the demand for a rich variety of categories, including modern, contemporary and antiquities, is strong.38 Pace Gallery chief Marc Glimcher announced the expansion of the gallery's global footprint to Seoul and is considering entering Japan. Once a rising force in the global market in the late 1980s, Japan now only accounts for just 4 per cent of the market. Nonetheless, in February 2021, Taro Kono, Japan's Minister for Regulatory Reform, promised a green light to art galleries, auctions and art fairs to transit art being sold or displayed through the country's freeport zones. Marc Glimcher acknowledged: 'If Japan truly reopens, it has the potential, once again, to become one of the centres of the art market in Asia.'39

2021 has proven that the market has the creative power, innovative capacity and resilience required to weather formidable storms. It is clear that a new generation of collectors and technological innovation are creating shifts in taste and demand that may redistribute market shares in years to come. The global market is beginning to embrace rather than resist these exciting evolutions. Might these be the art market's roaring twenties despite the storm? If the UK government backs the industry by threading carefully with regulatory changes and ensures that the UK market maintains both high and effective regulatory standards, the UK market could thrive in the years to come.


Footnotes

1 Pierre Valentin is a partner and Mona Yapova is a trainee solicitor at Constantine Cannon LLP.

2 ArtTactic, 'Contemporary Art Market Confidence Report' (July 2021).

3 ArtTactic, 'Raw Facts Auction Review – 1st Half 2021' (July 2021).

4 ibid.

5 Bloomberg, 'Art Galleries Discover That Their Business Model Is Covid-Proof' (February 2021).

6 The Art Newspaper, 'Christie's results for first half of 2021 show marked shift towards Asia, online and private sales—and female auctioneers' (July 2021).

7 ibid.

8 ibid.

9 INTERPOL, 'INTERPOL launches app to better protect cultural heritage' (May 2021).

10 New York Times, 'JPG File Sells for $69 Million, as “NFT Mania” Gathers Pace' (March 2021).

11 New York Times, 'Art's NFT Question: Next Frontier in Trading, or a New Form of Tulip?' (March 2021).

12 Clare McAndrew, The Art Market 2021 (Art Basel and UBS, 2021).

13 The Art Newspaper, 'Banksy-style NFTs have sold for $900,000—but are they the real deal and does it even matter?' (February 2021).

14 The Art Newspaper, 'But is it legal? The baffling world of NFT copyright and ownership issues' (April 2021).

15 Art Basel, 'Is blockchain the future of art? Four experts weigh in' (June 2018).

16 The Art Newspaper, 'Antiques dealer launches NFT—of his 17th-century Delftware vase' (March 2021).

17 The Art Newspaper, 'Crypto-creep accelerates as Sotheby's accepts Ether and Bitcoin for $5m Banksy painting' (May 2021).

18 The Art Newspaper, 'Basquiat NFT withdrawn from auction after artist's estate intervenes' (April 2021).

19 Financial Times, 'Immaterial gains: the NFT boom comes for fashion' (August 2021).

20 Clare McAndrew, The Art Market 2021 (Art Basel and UBS, 2021).

21 U.S.C. § 5312(a).

22 Directive (EU) 2015/849.

23 Bloomberg, 'Millions of Dollars of Artworks Left U.K. Before Brexit Cut-off' (January 2021).

24 Regulation (EU) 2019/880 of the European Parliament and of the Council of 17 April 2019 on the introduction and the import of cultural goods PE/82/2018/REV/1.

25 UKBS, 'UK Blue Shield concerned UK unprepared to prevent UK becoming a gateway for looted objects' (May 2021).

26 Fionnuala Rogers, Antiquities Coalition Policy Brief No 9, October 2021, 'Following the UK's Repeal of the EU Import Regulation in Great Britain, will Northern Ireland become a gateway to Europe for illicit cultural property? Recommendations for the UK to mitigate this risk and seize the opportunity to strike the right balance.'

27 Antiques Trade Gazette, 'Export licences will go digital in autumn 2021' (December 2020).

28 Directive 2014/60/EU of the European Parliament and of the Council of 15 May 2014 on the return of cultural objects unlawfully removed from the territory of a Member State and amending Regulation (EU) No. 1024/2012 (Recast) (Text with EEA relevance) implemented through the Return of Cultural Objects (Amendment) Regulations 2015.

29 Agreement on the withdrawal of the United Kingdom of Great Britain and Northern Ireland from the European Union and the European Atomic Energy Community 2019.

30 Trade and Cooperation Agreement between the European Union and the European Atomic Energy Community, of the one part, and the United Kingdom of Great Britain and Northern Ireland, of the other part.

31 Commission Regulation (EU) No. 731/2010 of 11 August 2010 concerning the classification of certain goods in the Combined Nomenclature.

32 Haunch of Venison Partners Ltd v. Revenue and Customs Commissioners [2008] 12 WLUK 359.

33 Tariff heading 9703 under Chapter 97 of the Combined Nomenclature (Works of Art, Collectors' Pieces and Antiques) in Council Regulation (EEC) No. 2658/87.

34 Council Regulation (EC) No. 338/97 and Commission Regulation (EC) No. 865/200.

36 Antiques Trade Gazette, 'Christie's says Asian buyers now dominant' (July 2021).

37 Antiques Trade Gazette, 'Christie's to open permanent saleroom in Hong Kong' (August 2021).

38 Art Market Monitor, 'Asian Art Market Continues Rapid Ascent at Sotheby's $270 M. Hong Kong Sales' (April 2021).

39 Artforum, 'Japan reworks tax structure in push to become arts hub' (May 2021).

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