4 Dec 2007
COMMISSIONER OF INLAND REVENUE v. HIT FINANCE LTD
- Citation
- COMMISSIONER OF INLAND REVENUE v. HIT FINANCE LTD
- Court
- Court of Final Appeal
- Case number
- FACV8/2007
Although the transactions were real, the introduction of Strategic and the circular borrowing were found to have the sole or predominant purpose of securing a tax benefit by enabling larger interest deductions; under s.61A the Commissioner was entitled to counteract that benefit by disallowing interest deductions in excess of the net proceeds actually received by the group, so the assessment on Hongkong International Terminals Limited was confirmed while the appeal against Hit Finance Limited was dismissed.