DIPNDepartmental Interpretation and Practice Note (Hong Kong)
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59) A DIPN is not binding authority and can be overturned by a court or administrative board of review.
The DIPN rejects the OECD's view that servers alone can constitute permanent establishments in certain circumstances: "[T]he Department will generally accept that the mere presence of a server does not constitute a PE.
The Hong Kong Associated Office Of Zhong Lun Law Firm) Hong Kong & Transfer Pricing: DIPN 45 Provides Additional Guidance