15 Mar 1991
HK-TVB INTERNATIONAL LTD v. COMMISSIONER OF INLAND REVENUE
- Citation
- HK-TVB INTERNATIONAL LTD v. COMMISSIONER OF INLAND REVENUE
- Court
- Court of Appeal
- Case number
- CACV88/1990
The Court held that the relevant profits did not arise in or derive from Hong Kong because the profit‑making activity consisted in exploitation of copyright rights exercisable only outside Hong Kong and the services or property exploitation giving rise to profit were performed or located outside Hong Kong; the incidental marketing and administrative activities in Hong Kong were insufficient to render the profits Hong Kong‑sourced, and accordingly the Board of Review's decision that the taxpayers were not liable to profits tax was affirmed.