Hong Kong Tax Authority indicates a server in Hong Kong may constitute a permanent establishment
Hong Kong’s Inland Revenue Department (IRD) recently issued a revised practice note (Revised DIPN 39) which indicates that a non-Hong Kong resident enterprise which maintains only a server in Hong Kong, without the involvement of human activities in Hong Kong, is now exposed to tax in Hong Kong. This change in position appears to be a result of the recent change to the definition of “permanen…
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