Clifford Chance

Commissioner's appeal in a source of profits case dismissed by the Court of Appeal

23 March 2012

Li & Fung (Trading) Limited ("LFT") was in dispute with the Inland Revenue on its offshore claim. Both the Board of Review and the Court of First Instance held that the commission income earned by LFT was offshore source and not chargeable to Hong Kong profits tax. The Inland Revenue was dissatisfied with the rulings, and appealed to the Court of Appeal on the question of the source of the commission income by way of case stated. The Court of Appeal dismissed the Inland Revenue's appeal.

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