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
- HCIA3/2007
On the facts found by the Board, the taxpayer was sufficiently involved in the Mainland manufacturing activities (substance over form) such that part of its profits were manufacturing profits sourced in the Mainland; DIPN 21 applies and an apportionment on the usual 50:50 basis is appropriate; questions of agency and documentary form were irrelevant to the applicability of DIPN 21 in these facts; the Board's decision was correct and is affirmed.