Hong Kong Court Sources Singapore Stock Profits in Hong Kong

This article discusses the Hong Kong Court of Final Appeal's decision in the Kim Eng Securities case in March 2007 regarding the source of a stockbroker's commission income for Hong Kong profits tax purposes. The court's judgment is regrettably short on legal analysis and difficult to reconcile with both precedent and the facts. The article argues that the court failed to recognize that the proximate cause of the income was the execution of transactions in Singapore, and therefore the income should have been held to have its source outside Hong Kong