26 Mar 2025
SAMSUNG SDI (HONG KONG) LTD v. COMMISSIONER OF INLAND REVENUE
- Citation
- [2025] HKCFI 1282
- Court
- Court of First Instance
- Case number
- HCIA7/2022
The Court held there was no error of law in the Board's Decision: the Board was entitled to assess the evidence for sufficiency and reliability, to apply the statutory burden on the taxpayer, and to refuse the appellant's invited findings because the evidence was piecemeal, extrapolations were unreliable and the effective cause of the profits was not established as offshore; accordingly the appeal was dismissed.