Management activities conducted in the Mainland do not, of themselves, render the source of profits to be in the Mainland for Hong Kong profits tax purposes.
tax
Statutory interpretation in tax law requires ascertaining meaning from text, context and purpose; beneficial construction favouring taxpayer is not appropriate.
Tax legislation is construed by giving words their ordinary meaning in context; legislative purpose resolves ambiguity but cannot override clear statutory language.
An organisation engaged in political advocacy and law reform can qualify as charitable, as generating public debate on matters of public interest satisfies the public benefit requirement.
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