Hong Kong Case Law: Decisions & Judgments | LexChat

Hong Kong Case Law

Tax avoidance transaction tests
  • 3 Dec 1999

    YICK FUNG ESTATES LTD v. THE COMMISSIONER OF INLAND REVENUE

    Citation
    YICK FUNG ESTATES LTD v. THE COMMISSIONER OF INLAND REVENUE
    Court
    Court of Appeal
    Case number
    CACV313/1998

    Court held that s18E should be construed in light of legislative history and the presumption that profits tax is annual; Commissioner is not entitled under s18E to adopt a basis period exceeding 12 months for businesses commenced before 1 April 1974. However, the change of accounting date was a "transaction" caught by s61A and, on an objective assessment of the s61A factors (notably timing and result), the change was entered into for the dominant purpose of obtaining a tax benefit; accordingly the Commissioner validly counteracted that benefit under s61A and could assess the relevant profits,…