Income Tax - Source Principle Refined?

13 Pages Posted: 26 Feb 2007

See all articles by Liu Hern Kuan

Liu Hern Kuan

Inland Revenue Authority of Singapore


The Privy Council had in the Hong Kong case of C.I.R. v. Hang Seng Bank Ltd. propounded a basic principle to assist courts in the determination of the source of profits for tax purposes. The Privy Council has recently reconsidered the basic source principle in the case of Commissioner of Inland Revenue v. HK-TVB International Limited ("TVBI case"), a case on appeal from the Hong Kong Court of Appeal. This case throws fresh light on the doctrine of source in the Hong Kong context and invites comment.

Suggested Citation

Hern Kuan, Liu, Income Tax - Source Principle Refined?. Singapore Journal of Legal Studies, pp. 566-578, 1992, Available at SSRN:

Liu Hern Kuan (Contact Author)

Inland Revenue Authority of Singapore ( email )

55 Newton Road
Revenue House
Singapore, 307987
+65 6351 2030 (Phone)
+65 6351 2077 (Fax)


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