6 May 1985
SINOLINK OVERSEAS LIMITED v. COMMISSIONER OF ISLAND REVENUE
- Citation
- SINOLINK OVERSEAS LIMITED v. COMMISSIONER OF ISLAND REVENUE
- Court
- Court of First Instance
- Case number
- HCIA1/1985
On the facts the activities that collectively produced the disputed profits—pre-contract management, contracting, and post-contract performance—were controlled and carried out from the company's Hong Kong head office; the salesmen were peripatetic agents and no permanent establishment abroad was shown; therefore the profits arose in and were derived from the Hong Kong business and the appeal is dismissed.