Following the decision in CG Lighting Limited v CIR, I would find it difficult to advise a Hong Kong taxpayer to pursue an appeal through the Hong Kong courts.
Consider this: If a taxpayer is unable to settle an objection against an assessment, the case will be referred to the Commissioner of Inland Revenue (CIR) for [...]

For many years, Hong Kong’s professional bodies and Chambers of Commence have lobbied the Government to amend the Inland Revenue Ordinance to allow group loss relief. Of the many arguments advanced for the introduction of such legislation, the following have consistently found support from lobbyists:
Corporate groups in Hong Kong may:
• pay tax as a group [...]

The facts of the case are that Li and Fung (“L&F”) assisted its customers in connection with the manufacture, sale and purchase of goods, for which it received a commission of 6% of the total FOB value of the customer’s export sales. L&F had entered into contracts with its offshore affiliates to perform certain [...]