The Commissioner of Inland Revenue (CIR) has issued a revised Departmental Interpretation and Practice Note No. 21: Locality of profits (DIPN) on 4 December 2009. This is extremely important to Hong Kong businesses as the question of source is fundamental to the taxation of profits.

Since DIPN have already been revised for several times, instead of summarizing the revised DIPN, this article only highlights the major departures from the Previous DIPN.

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TTA - Revised DIPN 21