Read the full judgment text of CACV 235/2021 on BabelCite. This Court of Appeal judgment.
1. Section 8(1A)(c) of the Inland Revenue Ordinance (Cap 112) (“ Ordinance ”), enacted to give a measure of relief from double taxation, “excludes income derived by a person from services rendered by him in any territory outside Hong Kong” from chargeability to salaries tax under certain specified conditions. Where a taxpayer has rendered services under a Hong Kong employment both within and outside Hong Kong during a relevant period, a question may arise, in the absence of any contractual alloc
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