2 Feb 1996
ORION CARIBBEAN LTD v. COMMISSIONER OF INLAND REVENUE
- Citation
- ORION CARIBBEAN LTD v. COMMISSIONER OF INLAND REVENUE
- Court
- Court of First Instance
- Case number
- HCIA5/1994
The Board of Review was entitled to find the profits arose where the money was lent (New York, Tokyo or Frankfurt) and, on the facts, the taxpayer did not carry on deposit‑taking business in Hong Kong and therefore was not a 'financial institution' for s.15(1)(i); consequently s.15(1)(i) did not apply and the interest profits were not chargeable to Hong Kong profits tax.