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?

Question

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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