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Hong Kong deductionsanti avoidance

Chapman Development Ltd v CIR

[2025] HKCA 956
JurisdictionHong Kong
CourtHong Kong Court of Appeal
Year2025
StatusBinding authority

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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John Wiley & Sons UK2 LLP & Wiley International LLC v The Collector of Stamp Revenue [2025] HKCFA 11
Randeep S Grewal v Commissioner of Inland Revenue [2025] HKCA 398
Samsung SDI (Hong Kong) Limited v Commissioner of Inland Revenue [2025] HKCFI 1282

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