TP Week International Tax Review
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Li & Fung wins Hong Kong verdict on source of commissions

05 May 2011


The Court of First Instance (CFI) has upheld the Board of Review’s decision in favour of Li & Fung, a sourcing, distribution and retailing company.

The judgment, issued on April 18 2011, stated that the source of its commission income came from outside Hong Kong, making it exempt from profits tax in the jurisdiction. It drew upon the ruling on the previous ING Baring case, where the Court of Final Appeal determined that the taxpayer’s income from trades executed on foreign stock exchanges was generated outside of Hong Kong.

Many of Li & Fung’s services were provided outside Hong...



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