Privy Council.

Lord Bridge of Harwich, Lord Brandon of Oakbrook, Lord Griffiths, Lord Ackner, Lord Jauncey of Tullichettle.

Judgment delivered 8 October 1990.

Profits tax – Hong Kong – Bank – Certificates of deposit in foreign currency bought and sold in Singapore and London – Whether profits ‘arising in or derived from’ Hong Kong – Inland Revenue Ordinance, sec. 14, 15(1)(i).

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