In its 2021 annual meeting with tax practitioners, the Hong Kong Tax Authority clarified the following issues related to the profits tax:When a Hong Kong resident enterprise has a “server permanent establishment (PE)” located outside Hong Kong which forms an essential and significant part of its e-commerce business, the Tax Authority has indicated that a part or all of its profits could be regarded as non-taxable offshore Hong Kong profits. The Tax Authority reconfirmed that the location of the server PE alone would not determine the locality of the profits, instead the core operations for the e-commerce transaction and the...