15 Oct 2008
NGAI LIK ELECTRONICS CO LTD v. COMMISSIONER OF INLAND REVENUE
- Citation
- NGAI LIK ELECTRONICS CO LTD v. COMMISSIONER OF INLAND REVENUE
- Court
- Court of Appeal
- Case number
- CACV22/2008
The Court upheld the Board of Review and the judge: the identified scheme had the effect of conferring a tax benefit by enabling profits to be shifted offshore through non-arm's-length transfer pricing and related arrangements, and having considered the seven matters in s61A(1) the dominant purpose was to obtain that tax benefit; quantification of the benefit was not required and s61A(2) assessments to counteract the benefit were lawful and applicable.