Recent Hong Kong Tax Cases: Cause for Alarm

Tax Notes International, Vol. 57, No. 5, p. 37, February 1, 2010

9 Pages Posted: 13 Feb 2010  

Jefferson P. VanderWolk

affiliation not provided to SSRN

Date Written: September, 24 2009

Abstract

A number of decisions by the Hong Kong courts and the Inland Revenue Board of Review have created serious doubts about whether Hong Kong's tax laws are being interpreted and applied in a reasonable way and whether a taxpayer can have confidence that a tax dispute in Hong Kong will be resolved on the basis of the legal authorities that govern the substantive tax issues. The first part of this article discusses a recent case on the source of employment income that illustrates the unsatisfactory state of affairs currently prevailing in this area. The second part of the article discusses recent cases on the source of profits from cross-border contract manufacturing, highlighting the fact that the tax authorities and the courts are using an analysis that conflicts with established case law and common sense.

Keywords: Hong Kong, tax, source

JEL Classification: K34

Suggested Citation

VanderWolk, Jefferson P., Recent Hong Kong Tax Cases: Cause for Alarm (September, 24 2009). Tax Notes International, Vol. 57, No. 5, p. 37, February 1, 2010. Available at SSRN: https://ssrn.com/abstract=1477843

Jefferson Peck VanderWolk (Contact Author)

affiliation not provided to SSRN

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