5 Aug 2022
THE COMMISSIONER OF INLAND REVENUE v. KOO MING KOWN AND ANOTHER
- Citation
- [2022] HKCFA 18
- Court
- Court of Final Appeal
- Case number
- FACV1/2022
Section 82A(1)(a) does not permit assessment of additional tax against an officer who merely signs a corporate tax return because the returns in issue were required to be made, and were made, by the corporate taxpayer (NT); s 57(1) makes officers answerable to ensure the company complies but does not impose on them a personal statutory requirement to make the company's return that would attract liability under s 82A(1)(a).