To provide certainty in the operation of the territorial source principle, the Inland Revenue Department has been providing advance rulings on the source of profits of a business for Profits Tax purposes. The service is subject to the payment of a fee. Further details are contained in Departmental Interpretation and Practice Notes No.31 ("Advance Rulings").
These notes have no binding force and do not affect a person's right of objection or appeal to the Commissioner of Inland Revenue, the Board of Review (Inland Revenue) or the Courts.
Issued by the Inland Revenue Department