IRD Disputes
Experienced representation in Inland Revenue Department disputes, tax investigations, objections, Board of Review appeals, and penalty negotiations in Hong Kong.
Our IRD Disputes Services
Tax Assessments and Objections
- Reviewing additional and estimated assessments issued by the Inland Revenue Department
- Preparing and filing valid objections within statutory time limits
- Drafting detailed grounds of objection supported by legal analysis and factual evidence
- Managing correspondence and information requests from the IRD during the objection process
- Negotiating settlements with the assessor and the Commissioner during the objection stage
- Advising on the purchase of tax reserve certificates and conditional standover applications
Board of Review Appeals
- Advising on the merits and strategy of appeals to the Board of Review
- Preparing statements of facts, submissions, and supporting evidence for Board hearings
- Representing taxpayers at Board of Review hearings
- Advising on the procedural and evidentiary requirements of Board proceedings
- Analysing Board of Review decisions for further appeal prospects
Court Appeals
- Advising on appeals from Board of Review decisions to the Court of First Instance
- Preparing cases stated for the opinion of the Court on questions of law
- Coordinating with barristers and senior counsel on court advocacy
- Managing appeals to the Court of Appeal and advising on further appellate options
- Advising on the costs implications of court proceedings
Tax Investigations
- Responding to IRD field audit and investigation enquiries
- Managing the disclosure of information and documents during investigations
- Advising on taxpayer rights and obligations during the investigation process
- Negotiating with the IRD investigation unit on the scope and conduct of enquiries
- Coordinating with criminal defence counsel where investigations involve suspected tax evasion
Back Duty Assessments
- Defending against back duty assessments under Section 60 of the Inland Revenue Ordinance
- Challenging the basis and quantum of additional assessments for prior years
- Advising on the statutory time limits applicable to back duty assessments
- Preparing factual and legal defences to allegations of fraud or wilful evasion
- Negotiating reductions in the amount of back duty assessed
Penalty Negotiations and Voluntary Disclosure
- Negotiating penalty reductions with the IRD on the basis of cooperation and mitigating factors
- Advising on the strategic benefits and risks of voluntary disclosure
- Preparing voluntary disclosure submissions to the Commissioner
- Managing the interaction between voluntary disclosure and penalty proceedings
- Advising on the implications of penalties for ongoing compliance and future filings
Our Approach
Strategic Case Management
Rigorous Preparation
Practical Negotiation
Clear Client Communication
