10 Apr 1987
COMMISSIONER OF INLAND REVENUE v. MR. GEORGE ANDREW GOEPFERT
- Citation
- COMMISSIONER OF INLAND REVENUE v. MR. GEORGE ANDREW GOEPFERT
- Court
- Court of First Instance
- Case number
- HCIA5/1986
Section 8(1) is concerned with the source of the employment (location of the contract/payment/employer) and not the physical place where duties are performed; s.8(1A)(a) is an extension that taxes income from services actually rendered in Hong Kong when the basic charge does not apply; because the respondent's employment source was located outside Hong Kong only income attributable to services actually rendered in Hong Kong is taxable and is to be apportioned on a time-in/time-out basis.