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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 .

Hang Seng Bank Limited [1991] 1 AC 306, HK-TVB International Limited v. CIR [1992] 2 AC 397 and CIR v. Orion Caribbean Limited [1997] HKLRD 924 and of the Court of Final Appeal in Kwong Mile Services Limited v. CIR [2004] 3 HKLRD 168, Kim Eng Securities (Hong Kong) Limited v. CIR [2007] 2 HKLRD 117 and ING Baring Securities (Hong Kong) Limited v.

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