Privy Council.

Lord Keith of Kinkel, Lord Templeman, Lord Oliver of Aylmerton, Lord Jauncey of Tullichettle, Sir Robert Megarry.

Judgment delivered 19 June 1991.

Profits tax – Hong Kong – Joint venture company established for development of land – Acquisition by joint venture company of 30 per cent shareholding in company owning valuable land through subsidiary – Sale by joint venture company of 25 per cent of its shareholding in that company – Whether shares acquired and disposed of ‘by way of trade or adventure in the nature of trade’ – Inland Revenue Ordinance, sec. 2(1), 14.

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