11 Dec 2007
NGAI LIK ELECTRONICS CO LTD v. COMMISSIONER OF INLAND REVENUE
- Citation
- NGAI LIK ELECTRONICS CO LTD v. COMMISSIONER OF INLAND REVENUE
- Court
- Court of First Instance
- Case number
- HCIA5/2007
Given the Board's unchallenged findings that prices were fixed after the event by accountants, arbitrary annual discounts redistributed profits among group companies, and management fees were nominal despite substantial services, the scheme operated to transfer assessable profits away from Ngai Lik and the dominant purpose of the transaction was to obtain a tax benefit; accordingly the Board's application of s.61A and its upholding of the Commissioner’s assessments were legally correct.