Construction Company’s Management Fee Deduction Rejected by SCIT

Share the Post:

CMSB v e Director General Inland Revenue

This case involves a tax dispute between a taxpayer company (CMSB) and the Inland Revenue Board (IRB) over the deductibility of management fees for two construction projects.

Background Facts

CMSB claimed deductions for management fees paid to a related company (CIWE) for two dam construction projects. IRB disallowed the deductions.

Issues in Dispute

Whether the management fees are deductible under Section 33(1) of the Income Tax Act 1967.

Taxpayer’s Contention

The fees were wholly and exclusively incurred for the completion of the projects which produced income.

IRB’s Contention

The fees cannot be matched to CMSB’s actual function as a management service provider. Hence not deductible.

Revenue Law

Section 33(1) allows the deduction of expenses wholly and exclusively incurred in producing income.

SCIT’s Decision

SCIT dismissed CMSB’s appeal. Held that CMSB failed to prove its case for deduction under the tax law.

Unfortunately, without the grounds of judgement, we do not have enough information to provide a complete analysis of this case.



The articles, templates, and other materials on our website are provided only for your reference.

While we strive to ensure the information presented is current and accurate, we cannot promise the website or its content, including any related graphics. Consequently, any reliance on this information is entirely at your own risk.

If you intend to use the content of our videos and publications as a reference, we recommend that you take the following steps:

  1. Verify that the information provided is current, accurate, and complete.
  2. Seek additional professional opinions, as the scope and extent of each issue may be unique.





  1. 核实所提供的信息是最新的、准确的和完整的。
  2. 寻求额外的专业意见,因为每个问题的范围和程度,可能是独特的。

Keep in touch with us so that you can receive timely updates


1. Website ✍️ 2. Telegram ✍️ 3. Facebook ✍

4. Blog ✍ 5. Google ✍

6. LinkedIn ✍

7. Threads ✍

8. 小红书 ID ✍ 2855859831

Share the Post:

Related Posts