Mr Andrew Lipow is an Australia resident. He was employed by Sugar Holdings Ltd ('SUGAR'), a company with central management and control in Hong Kong, as the Marketing Manager effective from 1 April 2020. He was recruited through a personnel agent in Australia. He attended the interview with a director of SUGAR in Australia and negotiated his terms of employment during the interview. His employment contract was signed in Hong Kong on the day he reported duty. His remuneration was credited to his bank account maintained in Hong Kong. During the course of his employment, he was required to travel to various Asian Pacific cities and spent 164 days outside Hong Kong for the year ended 31 March 2021. Being an Australian resident, he believed that he was only liable to Hong Kong salaries tax for services provided in Hong Kong and his income would be charged by time apportionment basis. The following is information about Andrew related to the year of assessment 2020/21: His monthly salary was $80,000. He also received a year-end bonus of $120,000 for the year. 2 SUGAR purchased a medical insurance policy for Andrew and his family at a cost of $18,000. Andrew received full reimbursement of medical expenses of $12,000 from the medical insurance scheme. 3 He rented a residential flat in Mongkok at a monthly rent of $30,000. He obtained a rental refund of $25,000 per month from SUGAR. On 1 October 2020, Andrew purchased a property in