Greg is a British National. On 1 April 2023, he entered into an employment contract with ABC Limited in London, under which he is employed as a legal counsel. ABC Limited is a company incorporated in the United Kingdom (UK). Being a leading management consulting firm in the UK, ABC Limited required a team of qualified solicitors as its legal counsels. Having worked in London for three months, Greg was seconded by ABC Limited to manage its Hong Kong branch from 5 June 2023. During the period from 5 June 2023 to 31 March 2024, Greg stayed in Hong Kong for 200 days. His remuneration for the period comprised a salary of HK$1,200,000 plus an apartment in Happy Valley, for which he paid rent of HK$50,000 in total. George declared all the relevant income in his 2023/24 tax return and, against which he claimed deduction of the subscription of HK$3,000 to the UK Law Society. In addition to his employment income, Greg also acquired a residential flat in Hong Kong ("the Property") with tenancy on 1 February 2024. In his 2023/24 individual tax return, Greg declared that rental income of HK$45,000 and claimed deduction of his payments for various expenses, including rates of HK$5,000, management fees of HK$24,000 and mortgage interest of HK$35,000. He also elected for Personal Assessment. Greg is married with no children. As his wife, Wendy did not come with him to Hong Kong, half of Greg's salary was paid in the UK to maintain Wendy's living expenses. Wendy did not have any income chargeable to tax in Hong Kong.