Source, Transfer Pricing and Anti-Avoidance: The Position After Ngai Lik and Datatronic

Journal
VanderWolk, J.P.
Hong Kong
Bulletin for International Taxation 2009 (Volume 63), No. 12
PriceUSD 45

This article discusses the decisions in the recent Hong Kong tax cases of Ngai Lik and Datatronic and the implications of these judgements for Hong Kong law regarding the source of profits, transfer pricing and tax avoidance. The decisions raise a number of issues that will require future clarification.