13 Jun 2008
COMMISSIONER OF INLAND REVENUE v. DATATRONIC LTD
- Citation
- COMMISSIONER OF INLAND REVENUE v. DATATRONIC LTD
- Court
- Court of First Instance
- Case number
- HCIA4/2007
On the facts found by the Board the taxpayer was involved in Mainland manufacturing activities (supplying materials, technical know‑how, plant and Hong Kong staff), so the Board correctly classified the profits as manufacturing profits with part sourced in the Mainland and correctly applied DIPN 21 to apportion profits on the ordinary 50:50 basis; form of documentation did not displace substance and agency analysis was irrelevant to applicability of DIPN 21.