Source of commission income - Court of First Inst... | KPMG | CN

Source of commission income - Court of First Instance affirms the application of ING Baring

Source of commission income - Court of First Inst...

Tax alert - Issue 10, April 2011

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Source of commission income - Court of First Instance affirms the application of ING Baring

In Li & Fung (Trading) Limited (HCIA 1/2010 and 3/2010), the Court of First Instance upheld the Board of Review's decision, finding in favour of the taxpayer that the source of the commission income was outside of Hong Kong. The Court declined to follow the Commissioner of Inland Revenue's argument that the income of the taxpayer should be apportioned on the basis that the management and supervision of overseas affiliates, which were undertaken in Hong Kong, were key factors in producing the taxpayer's profits.

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