Court of Appeal dismisses offshore claim by CG Lighting Ltd

Court of Appeal dismisses offshore claim by CG Li...

Tax alert - Issue 6, March 2011   In handing down its decision in CG Lighting Ltd v CIR (CACV 119/2010), the Court of Appeal has dealt a further blow to taxpayers claiming that arrangements, similar to contract processing arrangements, should enjoy equivalent tax treatment (i.e. only 50 percent of profits are subject to Profits Tax). The Court affirmed the decision of the Court of First Instance that the taxpayer was a trading company that bought and sold finished goods. The Court held that it was not a manufacturer of the lighting products which it sold for a profit.


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