3 May 2010
COMMISSIONER OF INLAND REVENUE v. C G LIGHTING LTD
- Citation
- COMMISSIONER OF INLAND REVENUE v. C G LIGHTING LTD
- Court
- Court of First Instance
- Case number
- HCIA8/2009
The Court held the profit‑producing transactions were the sales of finished products to customers effected in Hong Kong; the taxpayer's design, supply of raw materials and management involvement in manufacturing undertaken by a non‑agent subsidiary were antecedent or incidental and must be disregarded for s.14 sourcing. Therefore the Board erred in treating those manufacturing‑related activities as part of the profit‑producing transactions and the appeal is allowed.