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Volume 1 Fifth Supplement

Publication Date: Oct 1978

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DIGEST OF CASES REPORTED

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  Decision No. Download
PROFITS TAX    

Additional tax—failure to disclose profits derived from sale of land—taxpayer's honest belief that sale was not trading transaction—reliance on professional advice—whether taxpayer liable to a penalty assessment under section 82A of the Inland Revenue Ordinance—whether there was reasonable excuse  

BR80/76 Download BR80/76 (DOC) EN - English Download BR80/76 (PDF) EN - English

Real property recently acquired resold to company at higher price— allotment of shares in company in satisfaction of purchase money—shares unsold—whether profits derived from resale of property chargeable to tax  

BR18/76 Download BR18/76 (DOC) EN - English Download BR18/76 (PDF) EN - English

Redevelopment of inherited properties—identity of properties changed—sale—whether profits chargeable to tax  

BR12/74 Download BR12/74 (DOC) EN - English Download BR12/74 (PDF) EN - English

Taxpayer acquiring shares by way of exchange—whether the market value of its shares issued at the date of exchange is the real cost to itself of the shares so acquired   

BR2/77 Download BR2/77 (DOC) EN - English Download BR2/77 (PDF) EN - English

Taxpayer requiring capital for expansion of business—share exchange transaction—acquired shares sold at a profit to finance business—whether shares acquired in the course of a scheme of profit making  

BR11/76 Download BR11/76 (DOC) EN - English Download BR11/76 (PDF) EN - English
SALARIES TAX    

Taxpayer appointed general manager of Hong Kong company by affiliated foreign company—contract of employment enforceable in foreign country—performance of duties in and outside Hong Kong—salary paid by Hong Kong company but reimbursed by foreign company—whether situs of employment in Hong Kong  

BR64/76 Download BR64/76 (DOC) EN - English Download BR64/76 (PDF) EN - English