Read the full judgment text of HCIA 000005/1989 on BabelCite. This HCIA judgment.
1. These are appeals from a decision of a Board of Review, by way of case stated by the Board under section 69 of the Inland Revenue Ordinance ("the Ordinance"). The material facts are identical in each case. They are as follows : The taxpayer was incorporated in Hong Kong. At all relevant times, it has carried on in Hong Kong a general insurance business; i.e. not a life insurance business. It has earned interest on moneys placed on deposit outside Hong Kong ("the overseas interest income"). In