Required:

$($a$)$ Assume you are the tax adviser, explain to the management of FUK regarding the

proposed share acquisition of FOOD in respect of utilization of tax loss, with reference to

the relevant Inland Revenue Ordinance related to anti$-$avoidance provisions.

$(15$ marks$)$

$($b$)$ In respective of anti$-$avoidance provisions in Inland Revenue Ordinance, there are general

anti$-$avoidance provisions as well as specific anti$-$avoidance provisions. Explain the two

general anti$-$avoidance provisions and cite one example or case for each anti$-$avoidance

provision to illustrate its application.