Read the full judgment text of HCIA 000002/1994 on BabelCite. This HCIA judgment.
1. This is an appeal by the Commissioner of Inland Revenue (the Commissioner) by way of case stated under the provisions of Section 69 of the Inland Revenue Ordinance Cap. 112. In issue are four profits tax assessments, totalling $330,341.00. The Respondent (which I shall call the Taxpayer) objected to these assessments on the ground that the profits did not arise in nor were derived from Hong Kong.