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Abstract

The aim of this article is to show how a series of old Australian and New Zealand tax cases is somewhat unexpectedly acquiring a new lease of life in Hong Kong. More surprisingly still, the new-found relevance of these cases is largely in fields of commercial endeavour which were unimagined when they were decided but which now account for a very substantial part of Hong Kong’s economy. In particular, it has transpired that the old Australian and New Zealand cases bear directly on the taxation of, first, Hong Kong firms (and Hong Kong subsidiaries of foreign firms) involved in certain forms of joint-venture manufacturing in the Chinese mainland and, secondly, financial institutions. Moreover, the issues to which the old Australasian cases relate are not trivial; on the contrary, they relate to basic questions of liability. Consequently, the revenues at stake are substantial.

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