7 Mar 2011
COMMISSIONER OF INLAND REVENUE v. C G LIGHTING LTD
- Citation
- COMMISSIONER OF INLAND REVENUE v. C G LIGHTING LTD
- Court
- Court of Appeal
- Case number
- CACV119/2010
The Court held that the relevant profit-producing transactions were the sales to the Taxpayer's customers in Hong Kong; manufacturing by the Mainland subsidiary was an antecedent/offshore activity and could not be used to apportion profits offshore; therefore the Board erred in treating the mainland activities as creating offshore source and the appeal is dismissed.