Read the full judgment text of FACV 000011/2006 on BabelCite. This FACV judgment was delivered on 29 March 2007.
1. Two aspects of revenue law are before the Court. The first is the oft-litigated one of whether profits are of Hong Kong source so as to be taxable here or of foreign source so as not to be taxable here. All the profits concerned are those of a Hong Kong stockbroker (“the Taxpayer”) from four types of income earned on its customers’ dealings on foreign stock exchanges. The first type is net commission or brokerage on those dealings. Each of the other three types flow from margin facilities
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