ING BARING SECURITIES (HONG KONG) LIMITED (formerly known as BARING SECURITIES (HONG KONG) LIMITED and presently known as MACQUARIE SECURITIES LIMITED) v THE COMMISSIONER OF INLAND REVENUE

Read the full judgment text of FACV 000019/2006 on BabelCite. This FACV judgment.

1. Whether profits are of Hong Kong source and therefore taxable or of foreign source and therefore not taxable is a practical, hard matter of fact.  And it is a matter on which there is room for reasonable minds to differ.  So there can be circumstances in which the matter can reasonably be decided either way.  In the present case, the Board of Review did not actually decide the issue of source one way or the other.  Instead the Board simply held that the taxpayer had not discharged its onus un

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