Hong Kong Case Law

9 May 2025

RANDEEP S GREWAL v. COMMISSIONER OF INLAND REVENUE

Citation

[2025] HKCA 398

Court

Court of Appeal

Case number

CACV3/2024

The Court affirmed that under s8(1) IRO the place where services are rendered is not relevant to the general charge; the situs of the employment (deemed locality of the contract/employer residence/CMC) determines whether income arises in or is derived from Hong Kong, with place-of-service issues addressed by s8(1A)/(1B); the Board's factual finding that the employer (Green Dragon) was resident/controlled in Hong Kong was not perverse and the appeal is dismissed.

• Salaries tax
• Source of income
• Place where services rendered
• Situs of employment
• Central management and control (cmc)
• Deeming provisions (s8(1a),(1b))