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Hong Kong Court of Appeal clarifies situation for manufacturers

August 19, 2009

An important concession helpful to manufacturers using mainland China contract processors has been denied.

In a case that will be important for taxpayers using or planning to implement import processing arrangements, the Hong Kong Court of Appeal recently issued a decision (Commissioner of Inland Revenue v. Datatronic Limited (July 15 2009)) that denies the availability of the 50:50 concession to a Hong Kong-based seller of products manufactured in China by a related party. .

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