20 Mar 1987
COMMISSIONER OF INLAND REVENUE v. ASIA TELEVISION LTD.
- Citation
- COMMISSIONER OF INLAND REVENUE v. ASIA TELEVISION LTD.
- Court
- Court of First Instance
- Case number
- HCIA4/1986
The ordinary meaning of 'any person in Hong Kong through whom such non-resident person is in receipt of any income arising in Hong Kong' requires an intermediary through which the non-resident's income passes; a principal making direct payments on a principal‑to‑principal basis is not an 'agent' under s.2(b) of the Inland Revenue Ordinance, so the taxpayer was not liable under s.20A and the Board of Review was correct. Appeal dismissed.