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
- HCIA4/1994
On the facts the relevant lending transactions were effected offshore (New York, Tokyo or Frankfurt) and thus the profits arose outside Hong Kong; the taxpayer did not carry on deposit-taking business in Hong Kong and therefore was not a 'financial institution' for s.15(1)(i) purposes; consequently s.15(1)(i) does not operate to deem those receipts to arise in Hong Kong and the profits are not chargeable to Hong Kong profits tax.