THE COMMISSIONER OF INLAND REVENUE V. KOO MING KOWN AND ANOTHER

[2022] HKCFA 18 Court of Final Appeal 5 August 2022 • FACV1/2022 • 33 min read

4 cases cited (0 HK, 4 foreign)

Outcome

Appeal dismissed

the appeal is dismissed.

Source: [2022] HKCFA 18, Court of Final Appeal, decided 5 August 2022. Read directly from the judgment.

Judges (5)

Cheung Coram Fok Coram Gleeson Coram Ribeiro Coram Stock Coram

Counsel (5)

Department of Justice Firm Elizabeth Cheung Counsel Respondent Eugene Fung Counsel Amicus Curiae John Leung, as Counsel Amicus Curiae Stewart Wong Counsel Respondent

Parties (3)

Commissioner of Inland Revenue Respondent Koo Ming Kown Applicant Murakami Tadao Applicant

Summary

The Commissioner of Inland Revenue appealed regarding the proper interpretation of provisions allowing the Commissioner to raise additional assessments after the expiry of the normal time limit. The case concerned two taxpayers and raised questions about the meaning of 'fraud or wilful evasion' and 'loss of tax' under the Inland Revenue Ordinance. The appeal addressed important questions of tax law.

Statutes Cited

Criminal Procedure Ordinance

s 101E

Inland Revenue Ordinance (Cap 112)

Cases Cited (4)

HK (4)

(2019) 22 HKCFAR 392 [2018] HKCFI 2593 [2021] 3 HKLRD 642 [2021] HKCA 1833

Related cases

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[2025] HKCFA 11 HKCFA

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Judgment

Read the full judgment on the official Hong Kong Courts portal.

Source: HKLII ([2022] HKCFA 18)