3.2.87
SECRET
69
132.
The cost to the revenue of these two proposals
will be approximately $25 million both in 1987-88 and in
subsequent years.
"Time Apportionment" Basis of Taxation
133.
In the area of tax legislation there is always
some tidying up to be done either on grounds of equity or
to improve the administration of the system. In recent
years the assessment to salaries tax of employees who
render services both within and outside Hong Kong has been
a growing area of dispute between the Inland Revenue
Department and taxpayers. These disputes, which are
commonly referred to as "time apportionment" cases,
involve claims that certain income from employment should
be excluded from assessment. As the law now stands, the
question to be considered in each claim for time
apportionment is essentially one of fact, involving
examination of all the circumstances surrounding the
employment of, and the duties performed by, the employee.
SECRET
t