Read the full judgment text of HCIA 000001/1997 on BabelCite. This HCIA judgment was delivered on 14 July 1997.
1. At the beginning of 1989, the Respondent-taxpayer found itself in the happy position of being awash with US dollars. Between 4th January and 31st March, it used these dollars to purchase Japanese Yen worth HK$99.8m. Unfortunately, the taxpayer took an exchange loss on these purchases. It claimed, and initially was allowed, these losses as deductions against profits tax. Later, however, an assessor of the Inland Revenue Department issued additional assessments which disallowed the exchange los