4 Feb 2025
SINOLINK SHANGHAI INVESTMENTS LTD v. COMMISSIONER OF INLAND REVENUE
- Citation
- [2025] HKCFI 544
- Court
- Court of First Instance
- Case number
- HCIA1/2024
The court concluded the proposed appeal raised proper questions of law with a reasonable prospect of success because the Board's conclusions on the effect of the Investment Agreement and on whether sums were realised or anticipated implicated matters of contract construction and legal characterisation (mixed law and fact) and appellate law (Edwards v Bairstow test); leave granted limitedly (Question (a) excluding new MLO argument) and other identified questions permitted to proceed to appeal.