Privy Council.

Lord Nolan, Lord Nicholls of Birkenhead, Lord Steyn, Lord Hoffmann and Lord Clyde.

Judgment delivered 23 June 1997.

Profits tax – Hong Kong – Cayman Islands company formed to avoid Hong Kong profits tax on loan transactions – Company’s business managed by parent in Hong Kong – Whether profits liable to tax as ‘profits arising in or derived from Hong Kong’ – Inland Revenue Ordinance (Hong Kong), s. 14(1).

  This was an appeal by the Commissioner of Inland Revenue from the judgment of the Hong Kong Court of Appeal that the taxpayer (‘OCL’), was not liable to Hong Kong profits tax.

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