This article examines Hong Kong's source rules with the aim of providing useful comparative benchmarks for thinking about them in the context of the current debate on residence/source taxation. The article also identifies various contentious areas that continue to vex both Hong Kong taxpayers and tax administrators, and queries whether the residence/source dichotomy in the Hong Kong context is illusory. The article concludes that the "facts and circumstances" rules for source of profits applied in Hong Kong are the product of a very different era, and it must be asked whether they are now appropriate for modern commerce. Yet despite all these problems, in the Hong Kong context, the best cure may be found from within its "troublingly successful system" and not by enacting statutory source rules.