4 Apr 2023
CHAPMAN DEVELOPMENT LTD v. COMMISSIONER OF INLAND REVENUE
- Citation
- [2023] HKCFI 893
- Court
- Court of First Instance
- Case number
- HCIA6/2022
Leave to appeal was granted on two identified questions of law because the proposed appeal was reasonably arguable: (1) whether the Board erred in law by failing to treat variation of the management agreement by conduct as established on the facts; and (2) whether the Board erred in its application of s.61A by failing to accept the alternative hypothesis that profits would have been offshore if the taxpayer had performed the management work. The delay ground failed because no reasonably arguable question of law was identified.