TNAG-1641-FCO40-2288-Budget-of-Hong-Kong-1987 — Page 219

3.2.87

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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.

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