8 Feb 2024
WISE PEARL LTD v. THE COMMISSIONER OF INLAND REVENUE
- Citation
- [2024] HKCFI 439
- Court
- Court of First Instance
- Case number
- HCIA5/2023
Leave to appeal refused and summons dismissed because the proposed grounds raised questions of fact or hypothetical issues rather than proper questions of law; the Board's findings that the appellant was a trader and that its profits were Hong Kong sourced were supported by evidence and not perverse; the appellant failed to prove it had the requisite 'relevant interest' in the Shenzhen Buildings for 2010/11 under applicable PRC law and so was not entitled to IBA for that year; no jurisdictional error by the Board in declining to bind the Commissioner to DIPN 21.