Read the full judgment text of HCIA 000005/1994 on BabelCite. This HCIA judgment was delivered on 2 February 1996.
1. In this appeal we are called on to resolve a dispute, about profits tax, between Orion Caribbean Limited, in voluntary liquidation ("the taxpayer"), a company incorporated in the Cayman Islands but which carried on business in Hong Kong, and the Commissioner of Inland Revenue ("the Commissioner"). In order to explain the issues which divide the parties, it is necessary to state first the relevant charging provisions in the Inland Revenue Ordinance, Cap.112 ("the Ordinance") upon the true effe