Transcription of Departmental Interpretation And Practice Notes - No
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Departmental Interpretation And Practice Notes - No
Inland Revenue Department The Government of the Hong Kong Special Administrative Regionof the People's Republic of China Departmental Interpretation AND Practice Notes NO. 21 (REVISED) LOCALITY OF PROFITS These Notes are issued for the information of taxpayers and their tax representatives. They contain the Department s Interpretation and practices in relation to the law as it stood at the date of publication. Taxpayers are reminded that their right of objection against the assessment and their right of appeal to the Commissioner, the Board of Review or the Court are not affected by the application of these Notes . These Notes replace those issued in December 2009. CHU Yam-yuenCommissioner of Inland Revenue July 2012 Our web site : Departmental Interpretation AND Practice Notes No.
TVBI at 407C-D: “F. L. Smidth & Co. v. Greenwood [1921] 3 K.B. 583 was cited in Hang Seng Bank case and their Lordships do not doubt that Lord Bridge has in mind the judgment of Atkin L. J. in that case and in particular the passage when he said, at p. 593: “I think that the question is, where do the operations take place from which the
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