Privy Council.

Lord Templeman, Lord Goff of Chieveley, Lord Jauncey of Tullichettle,

Lord Lowry and Sir Christopher Slade.

Judgment delivered 20 July 1992.

Profits tax – Hong Kong – Hong Kong company exploited rights in television films outside Hong Kong – Whether profits of subsidiary ‘arising in or derived from Hong Kong’ – Inland Revenue Ordinance, sec. 14.

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