CHAPMAN DEVELOPMENT LTD V. COMMISSIONER OF INLAND REVENUE

[2026] HKCA 436 Court of Appeal 16 March 2026 • CACV450/2024 • 14 min read

12 cases cited (0 HK, 12 foreign)

Outcome

Leave to appeal refused

leave to appeal was refused by the Appeal Committee of the Court of Final Appeal in

Source: [2026] HKCA 436, Court of Appeal, decided 16 March 2026. Read directly from the judgment.

Judges (3)

Barma Coram Kwan Coram Yuen Coram

Counsel (6)

Department of Justice Firm J Chan & Lai Firm Elizabeth Cheung Counsel Respondent Johnny Mok Counsel Appellant Sharon Yuen Counsel Appellant Stewart Wong Counsel Respondent

Parties (2)

Chapman Development Limited Appellant Commissioner of Inland Revenue Respondent

Case Significance

Chapman Development Ltd v. Commissioner of Inland Revenue [2026] HKCA 436 is a Court of Appeal judgment in a revenue dispute that had earlier proceeded through Chapman Development Ltd v. Commissioner of Inland Revenue [2024] HKCFI 2590 and Chapman Development Ltd v. Commissioner of Inland Revenue [2025] HKCA 956. The court recorded that 'leave to appeal was refused by the Appeal Committee of the Court of Final Appeal in' the matter, closing off the taxpayer's route to a further appeal within this litigation.

The judgment also draws on further Court of Final Appeal and Court of Appeal authorities together with several additional citations from the wider record, none of which are attributed to named parties beyond the Chapman Development Ltd litigation itself.

What did the Court of Appeal record about further appeal in Chapman Development Ltd v. Commissioner of Inland Revenue [2026] HKCA 436?

The court recorded that leave to appeal was refused by the Appeal Committee of the Court of Final Appeal, closing off further appeal in a dispute that had earlier proceeded through Chapman Development Ltd v. Commissioner of Inland Revenue [2024] HKCFI 2590 and [2025] HKCA 956.

What earlier stages preceded [2026] HKCA 436 in the Chapman Development Ltd litigation?

The dispute had proceeded through Chapman Development Ltd v. Commissioner of Inland Revenue [2024] HKCFI 2590 at first instance and Chapman Development Ltd v. Commissioner of Inland Revenue [2025] HKCA 956 on appeal before the Court of Appeal recorded refusal of leave to appeal further.

Statutes Cited

Inland Revenue Ordinance (Cap 112)

Cases Cited (12)

UK (1)

[1991] 1 AC 306

HK (11)

(2004) 7 HKCFAR 275 (2007) 10 HKCFAR 417 (2009) 12 HKCFAR 296 (2011) 14 HKCFAR 750 (2014) 17 HKCFAR 567 [2009] 4 HKLRD 675 [2010] 3 HKLRD 110 [2011] 2 HKLRD 763 [2024] HKCFI 2590 [2025] 6 HKC 442 [2025] HKCA 956