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Hong Kong decisions
Decisions matching the current search
香港上訴法院駁回納稅人申請，拒絕就利得來源、agreement by conduct及程序公平問題批出終審法院上訴許可，並判令訟費。
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.
The Court of Appeal dismissed Wise Pearl Limited’s renewed leave application, holding the proposed grounds challenged factual findings rather than raising questions of law.
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.
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 Appeal held the upfront payment was Hong Kong-sourced and revenue, but found error in the source analysis for royalties and remitted that issue.
The High Court dismissed the taxpayer’s appeal on whether it carried on business in Hong Kong, but allowed the challenge on source-of-profits issues and remitted the matter for rehearing.
The Court of First Instance refused leave to appeal in a profits tax and building allowance dispute, holding the proposed grounds were largely factual or hypothetical.
High Court refused Foxconn leave to appeal against a tax decision, holding the source-of-profits and deductions complaints were factual and lacked reasonable prospect of success.
The Court of First Instance dismissed a profits tax appeal, holding the licensing business was carried on in Hong Kong, the royalties were Hong Kong-sourced, and the upfront payment was revenue.
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