Description

Please be reminded that this is an e-seminar which can be accessed anytime to obtain the CPD hours.

About the Seminar

Recently, the IRD has challenged the use by many taxpayers of the ‘provision of credit test’ as a basis for offshore claim on interest income.

On 24 September, TIHK has invited Mr. Stefano Mariani the solicitor advocate who is highly experienced in arguing revenue law cases, including offshore claims, before the Board of Review and higher Courts, to speak to us on how to handle IRD’s recent challenges on interest income.

In addition, the speaker will examine the new apportionment ruling on royalty income established in the recent Court of Appeal decision in Patrick Cox Asia and analyse its impact on future tax filings. He will also emphasise the importance of evidence in tax disputes, especially when the case would likely be appealed to the Board or a higher Court. He will also point out the importance of keeping the relevant documentation and explain what kind of documentation is relevant for a tax dispute following the decisions of the Court of First Instance in Samsung SDI and Sinolink Shanghai.

Members who have a tax dispute with IRD or expect to have one in future should attend this seminar. Even without tax dispute the seminar is a good reminder on how to prepare for a defence file pending future IRD’s challenges.

No CPD hours will be granted if you have already attended the live webinar on 24 September 2025.