15 Dec 1988
BANK OF INDIA v. COMMISSIONER OF INLAND REVENUE
- Citation
- BANK OF INDIA v. COMMISSIONER OF INLAND REVENUE
- Court
- Court of First Instance
- Case number
- HCIA4/1988
The court applied the operations test as formulated in the Hong Kong authorities (Sinolink and Hong Kong and Whampoa Dock) and held that the source of the discounting profits was Hong Kong because the decisive operations — contract formation, purchase/discounting, processing, treasury/funding and issuance of instructions — occurred in Hong Kong; routine presentation overseas by correspondent banks did not constitute the operations in substance producing the profit and therefore the Board of Review was correct to treat the profits as arising in or derived from Hong Kong.