Hong Kong Court of Final Appeal decides on transfer pricing case
July 29, 2009
On July 24 2009, the Hong Kong Court of Final Appeal (CFA) handed down its decision in the Ngai Lik Electronics Company vs CIR case.
The facts of the case involve a reorganisation, after which profits were made in new British Virgin Islands (BVI) entities, which had related-party transactions with Hong Kong; the Inland Revenue Department (IRD) raised additional assessments for the years 1991/1992 to 1995/1996 under the anti-avoidance provisions of section 61A.
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