8 Jul 2004
KWONG MILE SERVICES LTD v. COMMISSIONER OF INLAND REVENUE
- Citation
- KWONG MILE SERVICES LTD v. COMMISSIONER OF INLAND REVENUE
- Court
- Court of Final Appeal
- Case number
- FACV20/2003
The Court held the profits arose in or were derived from Hong Kong because the taxpayer earned them by marketing and selling the Mainland property in Hong Kong; the underwriting risk assumed in Guangzhou did not itself generate a premium or constitute the proximate source of the profits, so the profits are chargeable to Hong Kong profits tax.