Hock Heng Co Sdn Berhad v Director-General of Inland Revenue

Subject Matter

REVENUE — Income tax — Double taxation relief — Company resident in Malaysia with branch in Singapore — Double taxation agreement — All income of company taxable in Malaysia except Singapore profits — Computation of chargeable income — Losses incurred in Singapore in year of assessment — Whether deductible — Income Tax Act 1967, s 3 (a) — Double Taxation Relief (Republic of Singapore) Order 1966, art XVII1

[1980] AC 360; [1979] 2 WLR 788