17 Dec 1996
COMMISSIONER OF INLAND REVENUE v. MAGNA INDUSTRIAL CO LTD
- Citation
- COMMISSIONER OF INLAND REVENUE v. MAGNA INDUSTRIAL CO LTD
- Court
- Court of Appeal
- Case number
- CACV102/1996
On the facts found by the Board of Review the substantial profit-making activity — the sales network, authority of export managers to bind the company and contracts effected overseas — meant the profits in substance arose outside Hong Kong; the Board's conclusion was sustainable in law and the High Court judge erred in disregarding the subsidiary's separate legal identity without it being part of the Commissioner's case.