10 Mar 1992
COMMISSIONER OF INLAND REVENUE v. WARDLEY INVESTMENT SERVICES (HONG KONG) LTD.
- Citation
- COMMISSIONER OF INLAND REVENUE v. WARDLEY INVESTMENT SERVICES (HONG KONG) LTD.
- Court
- Court of First Instance
- Case number
- HCIA2/1991
Rebates received by the investment manager are not separate income arising from brokers' overseas transactions but form part of the taxpayer's remuneration under its management contracts; consequently the board erred in treating the disputed receipts as income to be sourced outside Hong Kong and its conclusion was erroneous.