Decision No
 

INTEREST TAX -
 

Inland Revenue Ordinance, Section 28(1)(a)─interest on bank time deposits─meaning of “accrues”
 

D13/84 (PDF file)

Inland Revenue Ordinance, Section 28(1)(a)─whether interest accruing upon a credit sale balance of price paid for the purchase of shares in an overseas corporation was “interest arising in or derived from” Hong Kong within the meaning of section 28(l)(a) and consequently subject to deduction under section 29
 

D5/85 (PDF file)

Consolidated account in foreign currency─rate of exchange to be applied─foreign currency depreciating─whether capital assets should be revalued in United States Dollars before calculating depreciation allowances
 

D25/83 (PDF file)

Assessment to additional tax─s. 82A Inland Revenue Ordinance─penalty assessment─tax undercharged─whether penalty assessment excessive
 

D4/84 (PDF file)

Partnership profits─set off of trading losses sustained by partners outside the partnership─election for Personal Assessment─section 42 of the Inland Revenue Ordinance
 

D6/84 (PDF file)

Assessment to additional tax─s. 82A Inland Revenue Ordinance─penalty assessment─repeated understatement after earlier investigation─whether additional tax excessive
 

D17/84 (PDF file)

Inland Revenue Ordinance, Section 14─profits arising in or derived from Hong Kong─source of profits─trading operations in Hong Kong─ manufacturing operations overseas
 

D19/84 (PDF file)

Assessment to additional tax─s. 82A of the Inland Revenue Ordinance─penalty assessment─whether ignorance or the employment of qualified accountants to handle the tax returns is reasonable excuse
  

D24/84 (PDF file)

Transfer of units in various buildings to subsidiaries or associated companies─whether the units were capital or trading assets─the principle in Sharkey v. Wernher considered
 

D26/84 (PDF file)

Trading─whether sale of the units in a building constituted trading or was the realization of an investment consequent upon a change of circumstances─appellant’s change of intention from that of investment in relation to the property concerned to that of trading
 

D27/84 (PDF file)

Trading of shares─CIR v. Dr. Chang Liang Jen (1977) HKTC 975 considered
 

D30/84 (PDF file)

Allowable deduction─Appellant undertook the completion of the building at its own cost in return for a 20 years lease─whether the cost of construction should be treated as an allowable deduction
 

D6/85 (PDF file)

Letting out of the flats in the name of a director of a company─liability to profits tax
  

D7/85 (PDF file)

Income arising in or derived from Hong Kong ─location or source of employment─“Totality of Facts” test
 

D2/84 (PDF file)

Inland Revenue Ordinance.  Section 8(1) of the─employee of multi-national group seconded to Hong Kong─whether office or employment of profit in Hong Kong
 

D10/84 (PDF file)

Inland Revenue Ordinance. Section 8(1), ( 1A ) & (IB)─income arising in or derived from Hong Kong ─meaning of “visits”
 

D11/84 (PDF file)

Inland Revenue Ordinance.  Section 59(1)─whether an assessment raised under the proviso to the section was valid─section 11(D)(b) of the Inland Revenue Ordinance─whether certain leave pay should be related back
 

D21/84 (PDF file)

Inland Revenue Ordinance.  Section 9(2)─the meaning of “room” within the context of the proviso to the section
 

D23/84 (PDF file)

Inland Revenue Ordinance, s. 12(l)(a)─mandatory contributions to National Insurance Scheme─whether deductible expense
 

D4/85 (PDF file)