Annual Report 2020

137 NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS 綜合財務報表附註 FOR THE YEAR ENDED 31ST DECEMBER, 2020 截至二零二零年十二月三十一日止年度 ANNUAL REPORT 2020 年度報告 28. 或然負債 香港稅務局（「稅務局」）早前於二零零六年六月至二 零一七年三月期間向本公司及本公司之若干附屬公 司發出估計╱額外評稅，稅額合共為 60,471,000 港 元。本集團已就相關估計╱額外評稅向稅務局提出 有效反對。 稅務局於二零一八年一月及二零一九年一月分別就 二零一一年╱二零一二年及二零一二年╱二零一三 年課稅年度之稅務糾紛再向本公司及本公司若干附 屬公司發出估計╱額外評稅合共 12,174,000 港元及 合共 4,260,000 港元，而本集團已於二零一八年二 月及二零一九年二月就該等估計╱額外評稅向稅務 局遞交反對書。 於二零一九年十月二十八日，本公司就上述稅務稽 查及二零一三年╱二零一四年至二零一八年╱二零 一九年課稅年度向稅務局提交和解建議書（「和解建 議書」），且和解建議書於二零一九年十二月十七日 獲稅務局批准。根據和解建議書，本集團無須計提 額外稅項撥備，而往年之稅項撥備 8,310,000 港元 及應付利息 1,773,000 港元已通過於過往年度購買 之 11,171,000 港元之儲稅券結算，此外，稅務局已 徵收 1,385,000 港元稅款罰金，並於截至二零一九 年十二月三十一日止年度內於損益確認。 28. CONTINGENT LIABILITIES The Hong Kong Inland Revenue Department (the “IRD”) had previously issued estimated/additional assessments to the Company and certain subsidiaries of the Company for the period from June 2006 to March 2017 amounting to HK$60,471,000 in aggregate. The Group had lodged valid objections with the IRD against the relevant estimated/ additional assessments. The IRD further issued estimated/additional assessments to the Company and certain subsidiaries of the Company in January 2018 and January 2019 in respect of year of assessment 2011/2012 and 2012/2013 respectively, demanding for tax in dispute of HK$12,174,000 in aggregate and HK$4,260,000 in aggregate respectively, and the Group had lodged objections with the IRD against these estimated/ additional assessments in February 2018 and February 2019. On 28th October, 2019, a settlement proposal (the “Settlement Proposal”) regarding above tax audit and the year of assessment 2013/2014 to 2018/2019 was submitted by the Company to the IRD, which was approved by the IRD on 17th December, 2019. Based on the Settlement Proposal, no additional tax provision is required to be provided by the Group and previous year’s tax provision amounting to HK$8,310,000 and interest payable of HK$1,773,000 were settled by the tax reserve certificates of HK$11,171,000 purchased in prior years. Further, a tax penalty of HK$1,385,000 was charged by the IRD and recognised in profit or loss during the year ended 31st December, 2019.