On the Source and Taxation of Royalties in Hong Kong

Journal
Author
Mariani, S.
Country
Hong Kong
Published Date
Issue
Asia-Pacific Tax Bulletin 2016 (Volume 22), No. 3
FormatPDF
EUR
45
| USD
50 (VAT excl.)

This article challenges the scholarly and judicial focus on the deeming provisions of section 15 of the Hong Kong Inland Revenue Ordinance to treat income arising from certain intellectual property rights as having a source, and therefore being taxable, in Hong Kong. The author examines the place of the trade or business test in section 14 of the Ordinance, and how it should be applied to contemporary transactions involving intellectual property rights.