Stefano Mariani

Tax

• Inland Revenue Board of Review D 11/19 35 IRBRD 416: Represented the taxpayer in an appeal against salaries tax assessments on terminal and post- employment payments.*
• Nomura Funds Ireland Plc v Collector of Stamp Revenue [2019] HKDC 406; [2019] HKDC 852; [2021] HKCA 1040: Represented the taxpayer before the District Court and Court of Appeal in an appeal on the question of whether a merger involving the transfer by operation of Luxembourg law of securities listed in Hong Kong was chargeable with stamp duty.*
• Inland Revenue Board of Review D 25/22: Represented the taxpayer in an appeal on whether profits arising from the sale, purchase, and leasing of certain industrial goods were chargeable to profits tax.*
• Health Brian Zarin v CIR [2020] 2 HKLRD 229; [2020] HKCA 147; [2021] HKCFI 1846; [2022] HKCA 412: Represented the taxpayer in a complex, multi-stage appeal against salaries tax assessments on terminal and post-employment payments (including multiple appeals before the Court of First Instance and Court of Appeal).*
• Inland Revenue Board of Review D9/21 36 IRBRD 385: Represented the taxpayer in an appeal on the question of whether a director’s fee was sourced in Hong Kong and so chargeable to salaries tax.*
• Inland Revenue Board of Review D 14/20 36 IRBRD 84: Represented the taxpayer in an ‘offshore claim’ litigation on the question of whether the taxpayer was chargeable to profit tax.*
• Tse Sum Ping v Collector of Stamp Revenue [2021] HKDC 379; [2021] HKDC 1250: Represented the duty-payer in an appeal against the denial of relief from Buyer’s Stamp Duty by the Collector of Stamp Revenue on the basis that the duty-payer was in his view not acting on her own behalf in the acquisition of multiple residential properties in Hong Kong.*
• John Wiley & Sons UK2 LLP & Anor v Collector of Stamp Revenue [2021] 5 HKLRD 20: Acted for the duty-payers on the procedural question of whether the High Court has jurisdiction to hear a stamp duty appeal.*
• Newfair Holdings Limited v Commissioner of Inland Revenue [2022] HKCFI 1133: Represented the taxpayer in an ‘offshore claim’ litigation on the question of whether the taxpayer was chargeable to profits tax.*
• Inland Revenue Board of Review D 2/22 36 IRBRD 551: Acted for the taxpayer in contesting the Commissioner’s withdrawal of acknowledgment of its charitable status under s.88 of the Inland Revenue Ordinance and, separately, on the question of whether deductions for building refurbishment under s.16F were allowable.*

* Including matters handled prior to joining Baker McKenzie.

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• Up and Coming lawyer for Tax: Hong Kong-based (International Firms) in Chambers Greater China Region (2022)
• Up and Coming lawyer for Tax: Hong Kong Law (International Firms) (China) in Chambers Asia-Pacific (2021)
• Next Generation Partner for Domestic and International Corporate Tax in Legal 500 Asia Pacific (2020-2022)
• Recommended Lawyer for Domestic and International Corporate Tax in Legal 500 Asia Pacific (2021-2022)
• Rising Star in Tax, Trusts and Estates in Euromoney’s Expert guide (2021-2022)

• Barrister of Lincoln's Inn
• Asian Institute of International Financial Law – Honorary Fellow
• Trust and Estate Practitioner (STEP)
• Revenue Bar Association (U.K.)
• International Fiscal Association (Hong Kong Branch)