If you remain dissatisfied with the Commissioner’s determination, you may lodge an appeal to the Board of Review under section 66 of the Inland Revenue Ordinance (“IRO”). The notice of appeal must be submitted within one month after the date of the Commissioner’s written notice of determination. It must be in writing and state clearly the grounds of appeal, together with supporting documents and a summary of facts.

The Board of Review is an independent statutory body that hears appeals against tax assessments. Hearings are generally conducted in private unless a public hearing is requested. The Board consists of a chairman, deputy chairmen, and members appointed by the Chief Executive. Taxpayers may represent themselves, appoint a tax advisor, or engage legal representation. The Board will consider both factual and legal arguments, and may request further clarification or documentation during the hearing.

If the Board confirms the assessment and you remain dissatisfied, you may further appeal to the Court of First Instance under section 69 of the IRO. This appeal must be lodged within one month from the date of the Board’s decision and must be based on a question of law. Appeals to the court are more formal and may involve significant legal costs.

In exceptional cases, further appeals may be made to the Court of Appeal and ultimately to the Court of Final Appeal, subject to leave being granted. These higher‑level appeals are rare and generally involve complex legal issues or matters of public interest.

Throughout the objection and appeal process, taxpayers should maintain complete records of correspondence, notices, and supporting documents. Timeliness is critical — failure to meet statutory deadlines may result in forfeiting the right to appeal. Taxpayers should also consider the financial implications of the disputed assessment, including provisional tax payments or tax reserve certificates, to manage cash flow during the appeal process.

The objection and appeal mechanism provides a structured pathway for resolving disputes, but strict adherence to procedural rules, deadlines, and documentation is required.

If you have any questions regarding the appeal process, please contact us at info@sg-cs.com for further assistance.

By K.F. Yan, Senior Accounting Manager