Hong Kong Tax News Flash

Dec 2009, Issue 13

The revised DIPN 21 on locality of profits - Adding clarity?

Departmental Interpretation & Practice Notes No. 21 - Locality of Profits ("DIPN 21") was first issued in 1992 and then revised in 1996 and 1998. Businesses and practitioners have urged the Inland Revenue Department ("IRD") to revise DIPN 21 to incorporate the legal principles established in the court cases handed down since 1998 and to state the IRD's latest view and assessing practice on the sourcing issue. On 4 December 2009, the IRD issued the long-awaited revised DIPN 21 ("revised DIPN 21") replacing the one revised in 1998. This news flash highlights some of the more important issues discussed in this latest revised DIPN 21 with our comments and observations.

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Contacts


Peter Yu: Hong Kong Tax Leader; Hong Kong; Tel: +[852] 2289 3122 Email
Tim Leung: Partner; Hong Kong; Tel: +[852] 2289 3055 Email
Reynold Hung: Partner; Hong Kong; Tel: +[852] 2289 3604 Email

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