Hong Kong taxation/

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Hor Ltd. is a company which has previous property trading records. It purchased a residential flat in mid-level and put up advertisement for letting. However, the company was not satisfied with the rental offered by the potential tenants, and the flat remained vacant for 6 months. Thereafter, the company allowed its managing director, Mr. Hor, to live there as quarters provided to him by the company. Two years later, Mr. Hor resigned from the directorship and sold all the shares he owned in Hor Ltd. to his son. One month later, Hor Ltd. sold the flat and made a gain on disposal of the flat by $3,000,000 Mr. Hor's son, the current managing director of the company, approaches you and asks you whether the gain on disposal of the flat is subject to Hong Kong profits tax. REQUIRED: Explain to Mr. Hor's son how strong his case is in that the profit is a capital gain and not subject to Hong Kong profits tax