№ files_lp_3_process_7_047717
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Board of Review decision concerning a profits tax appeal on the source of trading profits derived from the acquisition and sale of blinds and accessories, addressing the distinction between profit-producing transactions and antecedent or incidental activities under the Inland Revenue Ordinance.
Case No.:
D13/21
Jurisdiction:
Hong Kong
Subject Matter:
Profits tax – source of profits – offshore profits claim
Type of Document:
Board of Review decision
Relevant Legislation:
Inland Revenue Ordinance (sections 2, 14(1), 66, 68(4), (8), (9), Part 1 of Schedule 5)
Panel:
Chui Pak Ming Norman (chairman), Chung Koon Ying, Louis, Ng Cheuk Ping, Charmaine
Date of Hearing:
24 June 2021; 2 September 2021
Date of Decision:
17 December 2021
Appellant:
Private company incorporated in Hong Kong
Respondent:
Commissioner of Inland Revenue
Tax Year in Dispute:
2016/17 (with provisional tax for 2017/18)
Assessable Profits (Original):
HK$360,000
Tax Payable (Original):
HK$39,400
Assessable Profits (Revised):
HK$145,241
Tax Payable (Revised):
HK$5,991
Amount of Costs Ordered:
HK$25,000
Outcome:
Appeal dismissed; Revised Profits Tax Assessment confirmed
Key Issue:
Whether the Subject Profits were sourced offshore or arose in or were derived from Hong Kong
Related Activities:
Acquisition and sale of blinds and accessories; installation works; manufacturing by third party in the Mainland
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The product description is provided for reference. Actual content and formatting may differ slightly.
Year:
2021
Region / city:
Manchester
Topic:
Property law, Lease disputes
Document type:
Judgment
Court / institution:
High Court of Justice, Business and Property Courts in Manchester
Author:
Judge Hodge QC
Target audience:
Legal professionals, Property lawyers, Academics
Period of validity:
2021
Approval date:
1 April 2021
Date of changes:
None
Year:
2026
Region / City:
United Kingdom
Topic:
Tax law, Corporate taxation
Document Type:
Legal Analysis
Agency / Institution:
N/A
Author:
N/A
Target Audience:
Tax professionals, Corporate entities
Effective Period:
N/A
Approval Date:
N/A
Modification Date:
N/A
Note:
Year
Region / City:
United States, Houston
Subject:
Sales strategy, Customer service, Cross-selling
Document type:
Case study
Organization / Institution:
Pony Express Bank
Author:
Not specified
Target audience:
Business professionals, management
Effective period:
Not specified
Approval date:
Not specified
Date of changes:
Not specified
Year:
2009
Region / City:
Florida
Subject:
Lost Profits, Legal Claims
Document Type:
Legal Precedent
Organization / Institution:
Florida Courts
Author:
Not specified
Target Audience:
Legal professionals
Period of Validity:
Not specified
Date of Approval:
Not specified
Date of Changes:
Not specified
Year:
1993
Jurisdiction:
Tasmania, Australia
Subject:
Unexplained wealth, confiscation of criminal profits
Document type:
Legislative review report
Agency:
Department of Justice, Tasmania
Author:
Mr Damian Bugg AM QC
Target audience:
Parliament, legal professionals, public stakeholders
Period of implementation:
Part 9 commenced 1 March 2014
Review date:
2017
Bill implementation date:
2018
Public consultation deadline:
27 July 2018
Key provisions:
Restraining and forfeiting property, investigations, examinations, production of documents, wealth restraining orders, Public Trustee fees
Reference:
20855
Telephone:
6271 6270
e-mail:
[email protected]
Note:
Mr Robert Raether
Date:
25 January 2017
Document Type:
Regulation Impact Statement
Subject:
Diverted Profits Tax
Author:
Chris Toyne
Target Audience:
Decision Makers in Government
Period of Action:
Until final decision
Approval Date:
25 January 2017
Amendment Date:
N/A
Description:
A formal communication providing feedback on a Regulation Impact Statement related to a diverted profits tax.
Year:
2019
Date:
16 September 2019
Country:
Myanmar
Region / Areas Mentioned:
Kachin State; Shan State; Rakhine State; Bangladesh
Topic:
Military financing; corporate ties; human rights violations
Document Type:
Fact sheet
Organization:
United Nations Independent International Fact-Finding Mission on Myanmar
Institutional Context:
United Nations Human Rights Council
Key Individuals Mentioned:
Marzuki Darusman; Min Aung Hlaing; Soe Win
Military Organization Referenced:
Tatmadaw
Companies Referenced:
Myanmar Economic Holdings Limited (MEHL); Myanmar Economic Corporation (MEC)
Subject:
Business networks and financial resources used by the Myanmar military to support operations linked to persecution of ethnic groups
Related Events:
2017 clearance operations in Rakhine State; forced displacement of Rohingya population
International Issues Addressed:
Corporate responsibility; sanctions; arms embargo; international human rights law; international humanitarian law
Audience:
International community; governments; companies; investors; consumers
Year of decision:
2019
Jurisdiction:
Hong Kong
Subject:
Profits tax, special annual bonus, preferential dividends
Document type:
Court decision / Tax appeal ruling
Panel members:
Cissy K S Lam (chairman), Law Chung Ming Lewis, Richard Zimmern
Hearing dates:
23-24 May 2019
Decision date:
3 December 2019
Appellant:
Company operating a funeral parlour
Legal provisions:
Sections 16, 17, 68(4), (8), (9) and Part 1 of Schedule 5 of IRO (Chapter 112)
Relevant years:
2000/01–2011/12
Counsel for appellant:
Caspar Ng
Counsel for Commissioner:
Julian Lam
Key issues:
Deductibility of special annual bonus, characterization as preferential dividends, expenses “in the production of profits”
Outcome:
Appeal dismissed, costs of $25,000 imposed
Year:
2016/17
Institution:
College of Life and Environmental Sciences, University of Exeter
Type:
Assessment Guidelines
Audience:
Undergraduate and Postgraduate Students
Scope:
All taught programmes across disciplines and levels
Reference:
University Teaching Quality Assurance Manual (TQA)
Levels Covered:
Level 3 (pre-UG), Level 4 (first year UG), Level 5 (second year UG), Level 6 (final year UG), Level 7 (Masters)
Assessment Method:
Subjective marking, excluding MCQ, SAQ, or national criteria-based assessments
Year:
2016/17
Region / City:
Australia
Topic:
Performance Reporting, Health Regulation
Document Type:
Annual Report
Agency:
AHPRA
Author:
Ian Smith PSM, Michael Gorton AM
Target Audience:
Agency Management Committee, National Boards, External Parties
Period of Action:
1 July 2016 – 30 June 2017
Approval Date:
N/A
Date of Changes:
N/A
Context:
Annual report outlining the Performance Committee’s activities and initiatives during the 2016/17 period to improve the performance reporting framework for the Australian health regulation system.
Year:
From 2016/17
Region:
Moray
Country:
Scotland
Organisation:
Moray Council
Programme:
Duke of Edinburgh’s Award (DofE)
Office:
DofE Moray Office
Partner Organisation:
DofE Scotland
Document Type:
Administrative guidance leaflet
Subject:
Bulk purchasing of participant places and welcome packs
Related Agreement:
Partnership Agreements between Moray Council and Centres
Financial Process:
Enrolment fee collection and invoicing at end of financial year
Target Audience:
Centre Coordinators, Centre Admin Staff, DofE Leaders
Year:
2016/17
Academic Level:
Level 6/7
Program:
PGCE (Secondary) Drama
Modules:
Evidence-informed Learning, Teaching and Assessment; Professional Enquiry and Subject Leadership
Credits:
30 per module
Module Leader:
John Keenan
Semester:
1 & 2
Mode of Delivery:
Blended learning
Scheduled Hours:
300 per module
Contact Hours:
24 per module
Target Audience:
Secondary school trainee teachers
Website:
https://newmanpgcedramaenglish.wordpress.com
Year:
2016/17
Region / City:
Betsi Cadwaladr University Health Board
Theme:
Physical assault incidents on staff
Document Type:
FOI response
Institution:
Betsi Cadwaladr University Health Board
Author:
Betsi Cadwaladr University Health Board
Target Audience:
Public, staff, relevant authorities
Period of validity:
2016/17, 2017/18
Date of approval:
Not applicable
Date of changes:
Not applicable
Year:
2016/17
Organisation:
CSIRO
Program Name:
Undergraduate Vacation Scholarships – Astronomy and Space Science
Reference Number:
24322
Classification:
CSOF1.1
Stipend:
$1462.77 per fortnight (before tax)
Tenure:
10 weeks (28 November 2016 – 10 February 2017)
Locations:
Marsfield, Sydney; Perth, WA
Number of Projects:
12
Field:
Astronomy and Space Science
Eligibility:
Australian/New Zealand Citizens, Australian Permanent Residents, or international students with full work rights
Academic Requirements:
Minimum three years completed undergraduate study; strong academic record (credit average or higher); intention to undertake honours and/or postgraduate study
Application Requirements:
Selection of two preferred projects; cover letter and resume; academic results; optional referees
Contact Phone:
1300 984 220
Contact Email:
[email protected]
Project Fields of Study:
Electrical/Electronic Engineering; Computer Science; Computer Engineering; Astrophysics
Document Type:
Scholarship program announcement and project descriptions
Year:
2015
Region / City:
United Kingdom
Topic:
Funding for disabled students in higher education
Document Type:
Consultation response form
Organization:
Department for Business, Innovation and Skills
Author:
Paul Higgs, Higher Education Student Funding Policy
Target Audience:
Individuals, businesses, government bodies, charities, and educational institutions
Effective Period:
From 2016/17 onwards
Approval Date:
N/A
Date of Changes:
N/A
Year:
2017
Region:
South Africa
Subject:
Higher Education and Training Audit Results
Document Type:
Government audit briefing
Institution:
Auditor-General of South Africa
Target Audience:
Portfolio Committee on Higher Education and Training
Period Covered:
2016/17 financial year
Approval Date:
12 September 2017
Audited Entities:
Department of Higher Education and Training, TVET colleges, Universities, SETAs
Audit Outcomes:
Clean audits, unqualified with findings, qualified audits, disclaimer/adverse opinions
Control Issues:
Employee cost documentation, prepayments, asset register, leave accruals
Recommendations:
Implementation of controls, accountability measures, electronic document management
Year:
2016/17
Region / city:
Wandsworth
Topic:
Healthcare Services, Clinical IT, Medical Guidelines
Document Type:
Guidelines
Target Audience:
Healthcare professionals, medical staff
Effective Period:
2016-2017
Approval Date:
Not specified
Modification Date:
Not specified
Year:
2015/16 – 2016/17
Institution:
University of Ghana
Department:
Department of Information Studies
Course Level:
Undergraduate Level 100
Author:
Dr. Perpetua S. Dadzie
Acknowledgements:
Mr. Andy Adu Sarbeng, Teaching Assistant
Course Website:
http://sakai.ug.edu.gh/XXXXXXXXXXX
Support Contact:
School of Continuing and Distance Education, University of Ghana, Legon, Accra
Type of Document:
Study Guide
Teaching Method:
Problem-based learning
Delivery Format:
Online via Sakai LMS
Content Coverage:
Information concepts, communication, institutions of information management, information storage and retrieval, information technology
Assessment:
Individual assignments, group term paper, quizzes, tests
Target Audience:
Undergraduate students in Information Studies
Language:
English
Academic Year:
2015/16 – 2016/17
Year:
2016/17
Region / City:
England
Topic:
Netball, Sports Competition
Document Type:
Rules and Regulations
Organization:
England Netball
Author:
England Netball
Target Audience:
Schools, Netball Teams, Local Organizing Committees
Period of Validity:
Not specified
Approval Date:
Not specified
Date of Changes:
Not specified