This article examines the October 2007 judgment of the Court of Final Appeal in Hong Kong in ING Baring Securities and the Court's jurisprudence on the source of profits for Hong Kong tax purposes. The article argues that the Court's analysis and guidance in its decisions on the source question provide helpful clarification of the law, but the Court's jurisprudence does not deal comprehensively with the issues involved in determining the source of profits for Hong Kong tax purposes. Therefore, controversies over this issue will certainly continue to arise.