27 Jan 2010
HONG KONG SHENG KUNG HUI FOUNDATION v. COMMISSIONER OF INLAND REVENUE
- Citation
- HONG KONG SHENG KUNG HUI FOUNDATION v. COMMISSIONER OF INLAND REVENUE
- Court
- Court of First Instance
- Case number
- HCIA3/2009
The Court upheld the Board: on the facts it was reasonable to conclude the Church and Foundation changed intention from capital holding to a trading/development enterprise by September 1989 or December 1990; the appellants failed to discharge the statutory onus to show the s.88 proviso applied because they adduced no reliable evidence that profits were applied solely for charitable purposes, not substantially expended outside Hong Kong, or that the trade met either limb (a) or (b) of the proviso; appeals dismissed.