第19册第1增订本

attempt to vary settlement agreement — whether quantum excessive — co-operation   [英文案例]

deduction for losses — disposal of properties — intention at the time of acquisition — whether the properties are capital assets or trading assets — ss 14(1), 2(1),42(2) & 68(4) of the Inland Revenue Ordinance ("IRO")   [英文案例]

个人入息课税的入息总额–可容许扣除为产生出租物业收入而支付的利息–举证责任在上诉人身上–《税务条例》第42(1)及68(4)条

convertible participating certificates — annual income — profits from disposition — s 26 of the Inland Revenue Ordinance ("IRO")   [英文案例]

interest expenses attributable to the payment of dividend — s 16(1)(a) of the Inland Revenue Ordinance ("IRO")   [英文案例]

ss 2, 14(1) and 68(4) of the Inland Revenue Ordinance — whether a property is a capital asset or trading asset — intention of the taxpayer at the time of acquisition of the property must be genuinely held, realistic and realizable — burden of proof on the taxpayer   [英文案例]

s 42(1) of the Inland Revenue Ordinance — whether a global deduction of interest payable against the total taxable property income   [英文案例]

apportionment of income to services rendered outside of Hong Kong within meaning of s 8(1A)(a) of the Inland Revenue Ordinance ("IRO") — whether the time apportionment basis should be accepted — whether taxpayer discharged burden of proof in demonstrating that services rendered in Hong Kong was less than that calculated on the time apportionment basis   [英文案例]

deductions — whether reparation to employer "expenses" — ss 11D, 12(1)(a) and 68(4) of the Inland Revenue Ordinance ("IRO")   [英文案例]

extension of time for appeal — whether appellant established a proper case for an extension of time to file a notice of appeal under s 66(1A) of the Inland Revenue Ordinance ("IRO") — whether appellant was prevented by "reasonable cause" other than illness from giving notice of appeal to the Board of Review promptly   [英文案例]

gain on share option — Hong Kong sourced vs non-Hong Kong sourced employment — vesting period — services rendered in Hong Kong during non-Hong Kong sourced employment — time apportionment basis — severance payment — whether tax-exempt or not depends not on the label but on all the circumstances in which the payment was made — ss 8 and 9 of the Inland Revenue Ordinance ("IRO")   [英文案例]

home loan interest — refinance of mortgage — obtained or obtained wholly for the acquisition of a dwelling — s 26E of the Inland Revenue Ordinance ("IRO")   [英文案例]

payment upon termination in addition to payment in lieu — whether compensation   [英文案例]

s 12(1)(a) of the Inland Revenue Ordinance — whether the item of expenditure qualified as deductible expense   [英文案例]

source of income — whether arising in or derived from Hong Kong — statutory exemption — whether all services rendered outside Hong Kong — 60 days grace period — ss 8(1), 8(1A)(b), 8(1B) & 68(4)of the Inland Revenue Ordinance ("IRO")   [英文案例]

tenancy agreement between employer and employee — ss 8, 9(1), 9(2), 61 and 68(4) of the Inland Revenue Ordinance ("IRO")   [英文案例]

whether Revenue estopped from raising salaries tax assessments — whether payments made by employer constituted rental refunds — whether taxpayer intended to create a legally binding sub-tenancy agreement with a related company as landlord — whether letting arrangements constituted an artificial or fictitious transaction under s 61 of the Inland Revenue Ordinance ("IRO")   [英文案例]

whether severance payment and special notice payment income from employment   [英文案例]