ˇ§Source of profits ˇV ING Baring Securities case from the Court of Final Appealˇ¨
A seminar organised by The Institute on behalf of
The Taxation Institute of Hong Kong Educational Trust
The Court of Final Appeal handed down the judgment on 5 October 2007 for the ING Baring Securities (Hong Kong) Limited vs. The Commissioner of Inland Revenue case (FACV000019/2006).
The ruling has clarified some uncertainties surrounding the determination of source of profits. The decision has significant impact for both taxpayers and Inland Revenue Department. It also provides certain guidelines to the taxpayers who are currently engaged in corresponding with Inland Revenue regarding the source of profits.
With this in mind, our Institute has invited Mr. Kenneth Leung, Vice-President of the Institute to share his views with us. The seminar will cover the following topics:
- The concept of antecedent or incidental activities (ˇ§totality of facts testˇ¨) and its relevancy in
determining the source of profits
- The significance and importance of the Court of Final Appealˇ¦s decision in ING Baring case
- The impact of the case on DIPN 21 (ˇ§Locality of Profitsˇ¨) and the view from Inland Revenue
- The future impact of the decision over IRD and taxpayer
Details of the Seminar are as follows:-
Topic :
|
ˇ§Source of profits ˇV ING Baring Securities case from the Court of Final Appealˇ¨ |
Date :
|
28 March 2008 (Friday) |
| Time : |
6:30pm ˇV 8:30pm
(No refreshments provided) |
| Venue : |
Lecture Room A, The Joint Professional Centre
Unit 1, G/F., The Center, 99 Queenˇ¦s Road Central, Hong Kong |
| Speaker : |
Mr. Kenneth Leung
Vice-President of the Taxation Institute of Hong Kong |
| Language : |
Cantonese |
| Fee : |
HK$250 for TIHK member;
HK$350 for Non-member;
HK$300 for members of organizations of CPD Alliance (www.cpdalliance.org.hk) |
| CPD Credit : |
2 Hours |
| Maximum capacity : |
110 Seats |
Please fill in the registration form and return it to our office together with a cheque payable to ˇ§The Taxation Institute of Hong Kongˇ¨.
Due to limited space, registration will be accepted on a first-come-first-served basis upon payment received. Confirmation letter will be sent by email. Please present the confirmation letter when attending the seminar on 25 January 2008.
Yours faithfully,
Webster Ng
Chairman of Continuing Professional Development Committee
Download->SEMINAR
REGISTRATION FORM "Source of profits ˇV ING Baring Securities case from the Court of Final Appealˇ¨ˇ¨
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