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Hong Kong decisions
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The Court of Appeal dismissed Chapman Development Limited’s appeal in a profits tax dispute, upholding findings on deductibility, agreement by conduct, and section 61A.
Leave to appeal was granted in a profits tax dispute over whether annual concession payments were capital or revenue, with leave refused on one ground.
The Court of First Instance dismissed CAC International’s tax appeal, holding the Board of Review had properly used a de novo approach and correctly found trading intent in the property sales.
The Court of First Instance dismissed Samsung SDI (Hong Kong) Ltd’s inland revenue appeal, holding no error of law was shown in the Board’s source-of-profits analysis.
The court granted leave to appeal in an inland revenue case about whether shareholder-loan sums were interest and whether the profits were sourced in Hong Kong.
Court of Appeal refused leave to appeal in a profits tax case, holding the Board's findings on source of profits, deductions, and delay were open on the evidence.
The Court of First Instance held that Rollcash must indemnify ICBC International Wealth Investment for assessed profits tax arising from the Exercise under the tax indemnity deed.
Leave to appeal was refused in two linked inland revenue appeals concerning whether the Servicemen’s Guides Association was a charitable institution under s.88 IRO.
Court of Final Appeal held that Perfekta did not change its intention to trade the Lot; the Initial Payment was capital in nature and the assessment was annulled.
香港上訴法院審理利得稅爭議，涉及土地重建安排、意向轉變、資本與收入性質，以及是否准許修改上訴理由並發還評稅事宜。
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