Read the full judgment text of HCIA 000003/2003 on BabelCite. This HCIA judgment was delivered on 12 May 2004.
1. This is an appeal by the Appellant (the "Taxpayer") by way of a case stated pursuant to section 69 of the Inland Revenue Ordinance (Cap 112) against the decision D172/01 of the Board of Review (the "Board") dated 22 March 2002. The Taxpayer was incorporated in Hong Kong in 1985 and commenced business in the trading of polysilicon in 1994. It does not have any overseas office or any other form of permanent establishment outside Hong Kong. The Taxpayer was dissatisfied with the profits tax asse