19 Oct 2023
PATRICK COX ASIA LTD v. THE COMMISSIONER OF INLAND REVENUE
- Citation
- [2023] HKCFI 2676
- Court
- Court of First Instance
- Case number
- HCIA4/2023
The Board’s factual findings that the taxpayer conducted the licensing business in Hong Kong and that the profit‑producing acts (entering the Deed of Cooperation and granting sub‑licences) took place in Hong Kong were supported by evidence; accordingly the 40% royalties and the upfront payment were sourced in Hong Kong; the upfront payment was a revenue receipt received in the ordinary course of the taxpayer’s licensing business and not a capital sum, so the appeal is dismissed.