6 Aug 2004
LAM SOON TRADEMARK LTD v. THE COMMISSIONER OF INLAND REVENUE
- Citation
- LAM SOON TRADEMARK LTD v. THE COMMISSIONER OF INLAND REVENUE
- Court
- Court of First Instance
- Case number
- HCIA2/2004
The Court held that the Board of Review's factual findings — that the Appellant carried on business in Hong Kong and that the profit‑generating activities (granting of licences) were negotiated and agreed in Hong Kong by management based in Hong Kong — were reasonable and unassailable; accordingly the additional assessments under s60 were valid and there was no impermissible double taxation given the operation of the deeming provisions and allowance for prior 10% charge; appeal dismissed.