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Hong Kong
deductionsanti avoidance
Chapman Development Ltd v CIR
[2025] HKCA 956
Key Principle
Management/extraneous fees paid by a Hong Kong company to a related offshore (BVI) entity interposed between it and Mainland production are not deductible in the production of assessable profits under s.16(1) of the Inland Revenue Ordinance, and an artificial fee arrangement may be disregarded under the general anti-avoidance rule in s.61A.
Area of Law
tax
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