№ files_lp_4_process_3_091714
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Judicial record analyzing whether special annual bonuses paid to shareholders constituted deductible expenses or preferential dividends under Hong Kong profits tax law.
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
Price: 8 / 10 USD
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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
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
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