COMMISSIONER OF INLAND REVENUE v. TONG KWAN-CHE
- Citation
- COMMISSIONER OF INLAND REVENUE v. TONG KWAN-CHE
- Court
- Court of First Instance
- Case number
- HCIA1/1976
Under Hong Kong law and on the facts the taxpayer received no cash or notional taxed distribution and there is no provision in the Inland Revenue Ordinance treating capitalised reserves as dividends; therefore bonus shares allotted to a share trader in these circumstances carry no imputed cost and must be treated as costing nil for the purposes of computing assessable profits, reversing the Board's majority conclusion that par value could be imputed.