26 Apr 1985
BANQUE NATIONAL DE PARIS HONG KONG BRANCH v. COMMISSIONER OF INLAND REVENUE
- Citation
- BANQUE NATIONAL DE PARIS HONG KONG BRANCH v. COMMISSIONER OF INLAND REVENUE
- Court
- Court of Appeal
- Case number
- CACV129/1984
The Court held the 'interest' credited to head office on retained Hong Kong branch profits was not deductible because the bank, as the legal person chargeable under s.14, could not incur a liability to itself; r.3(2) of the Rules governs the method of ascertainment only and cannot displace the substantive deduction conditions in s.16 of the Inland Revenue Ordinance.