18 Apr 2011
COMMISSIONER OF INLAND REVENUE v. LI & FUNG (TRADING) LTD
- Citation
- COMMISSIONER OF INLAND REVENUE v. LI & FUNG (TRADING) LTD
- Court
- Court of First Instance
- Case number
- HCIA3/2010
The Board correctly identified that the profit-producing transactions were the sourcing and agency activities performed by overseas local affiliates; those activities occurred outside Hong Kong and thus the disputed profits were sourced offshore and not subject to Hong Kong profits tax. Apportionment was not required on the facts.