Loan interest income▸ D7/84• The sequence in determining the taxability of interestincome 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 indetermining source under s.14; and(b) if under s.14 it is decided that the interest is not subject toHong Kong taxThen the matter must be viewed again under s.15(1)(i) but thistime the place where the funds were provided is to bedisregarded as a factor in determining the source of the interest77

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Loan interest income ► S.15(1)(i) 。 sums, not otherwise chargeable to tax under this Part (i.e. not chargeable under s.14), received by or accrued to a financial institution by way of interest which arises through or from the carrying on by the financial institution of its business in Hong Kong, notwithstanding that the moneys in respect of which the interest is received or accrues are made available outside Hong Kong 。 Contrast to s.14: arising in or derived from HK What does "arises through or from" mean? Loan interest income is deemed taxable even though the loan is made available outside Hong Kong? 74
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Loan interest income ▸ D7/84 O 。 The sequence in determining the taxability of interest income of an Fl: о . 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
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D7/84 ◦ The sequence in determining the taxability of interest income of an FI: 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 It is talking about Hong Tax, Special Business, Calculating profit tax of financial instituition, loan interest income. Can you explain above paragraph in a simple way and with simple example?
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Loan interest income ► S.15(1)(i) 。 sums, not otherwise chargeable to tax under this Part (i.e. not chargeable under s.14), received by or accrued to a financial institution by way of interest which arises through or from the carrying on by the financial institution of its business in Hong Kong, notwithstanding that the moneys in respect of which the interest is received or accrues are made available outside Hong Kong 。 Contrast to s.14: arising in or derived from HK What does "arises through or from" mean? Loan interest income is deemed taxable even though the loan is made available outside Hong Kong? 74
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