EYEY

Hong Kong Court rules sub-licensing income is Hong Kong-sourced taxable income

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Hong Kong

  • Hong Kong's Court of First Instance (CFI) recently handed down a decision1 that ruled royalties from sub-licensing certain trademarks for use in Japan to be Hong Kong-sourced income and taxable in Hong Kong.
  • Activities performed by agents in Japan under the joint venture arrangement are not attributable to the Hong Kong taxpayer when determining its source of profits if they are not directly linked…

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