Loan interest income ▸ D7/84 • The sequence in determining the taxability of interest income of an Fl: . Consider s.14(1) first . If not chargeable under s.14(1), then consider s.15(1)(i) 。 Interpretation on s.15(1)(i): • ⋅ • (a) if the place where the funds are made available is a factor in determining source under s.14; and (b) if under s.14 it is decided that the interest is not subject to Hong Kong tax Then the matter must be viewed again under s.15(1)(i) but this time the place where the funds were provided is to be disregarded as a factor in determining the source of the interest 77

Loan interest income ▸ D7/84 • The sequence in determining the taxability of interest income of an Fl: . Consider s.14(1) first . If not chargeable under s.14(1), then consider s.15(1)(i) 。 Interpretation on s.15(1)(i): • ⋅ • (a) if the place where the funds are made available is a factor in determining source under s.14; and (b) if under s.14 it is decided that the interest is not subject to Hong Kong tax Then the matter must be viewed again under s.15(1)(i) but this time the place where the funds were provided is to be disregarded as a factor in determining the source of the interest 77