第24冊

s 69(1) of the Inland Revenue Ordinance (‘IRO’) – appeal against the Board’s finding of facts – proper questions of law – whether the questions are particularised and clearly identify the questions of law [英文案例]

salaries tax –application to state case – s 69 of Inland Revenue Ordinance (‘IRO’) [英文案例]

time to lodge appeal - appeal out of time - whether time to lodge appeal should be extended - salaries tax - source of income - whether at least some salaries were derived from a Hong Kong source - whether the 60-day rule applies - whether appellant can claim relief on ‘double taxation’ - Inland Revenue Ordinance (‘IRO’) ss 8, 66 and 68(4) [英文案例]

薪俸稅 –《稅務條例》第82A條

上訴 – 缺席聆訊 – 《稅務條例》第68條 [英文案例]

company interposed between appellant and group companies in the course of trading – transaction entered into for the sole or dominant purpose of obtaining tax benefits – ss 14, 16(1), 61, 61A and 68 of the Inland Revenue Ordinance (‘IRO’) [英文案例]

issue of apportionment – deductibility of expenses – anti-avoidance – ss 16(1), 17(1)(b), 61 & 61A of Inland Revenue Ordinance (‘IRO’) [英文案例]

source of profits – Taxpayer paid processing charges to Mainland factory for the manufacture of products – did profits arise partly in Hong Kong and partly in the Mainland – apportionment of profits – deductions for expenditure on prescribed fixed assets – ss 14 and 16G of the Inland Revenue Ordinance (‘IRO’) – Departmental Interpretation and Practice Note (‘DIPN’) Nos. 15 and 21   [英文案例]

special deduction and depreciation allowance – prescribed fixed assets – industrial building allowance – ss 2, 16(1), 16G, 18F, 37, 39B, 39E, 40(1), 66(3) and 68(4) of the Inland Revenue Ordinance (‘IRO’) – DPIN No 15 [英文案例]

absent from hearing – application for adjournment – s 68, 68(2B) and 68(2D) of the Inland Revenue Ordinance (‘IRO’) [英文案例]

locality of employment – whether reimbursement of relocation expenses upon taking up of employment and relocation allowance upon termination chargeable or not – ss 8(1)(a), 8(1A)(a), 12(1)(a) of the Inland Revenue Ordinance (‘IRO’) [英文案例]

payment on termination of employment – whether assessable to salaries tax – ss 8(1) and 9(1)(a) of the Inland Revenue Ordinance (‘IRO’) [英文案例]