29 Jul 2002
COMMISSIONER OF INLAND REVENUE v. KWONG MILE SERVICES LTD.
- Citation
- COMMISSIONER OF INLAND REVENUE v. KWONG MILE SERVICES LTD.
- Court
- Court of First Instance
- Case number
- HCIA1/2002
The majority of the Board was wrong in law to treat the assumption of the underwriting risk in Guangzhou as the source of the profits; the only reasonable conclusion on the facts found is that the underwriting risk only materialized into profits through marketing, sales and receipt of purchase moneys in Hong Kong and therefore the profit producing acts occurred in Hong Kong.