Mr Borrower has recently incorporated a trading company ('the Company') in Hong Kong and is currently arranging

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Question:

Mr Borrower has recently incorporated a trading company ('the Company') in Hong Kong and is currently arranging the following bank loans for different purposes:

Loan A - The bank loan money will be used to acquire an office which is to be used by the Company in its trading business. The office will be pledged as security for the loan.

Loan B - The bank loan money will be used to acquire an office which is to be rented out by the Company to earn rental income. The bank loan will be secured by a USD deposit placed with the same bank by Mr Borrower.

Loan C - The bank loan money will be used to acquire an office which is to be used by the Company's associate rent free. The office will be pledged as security for the loan.

Loan D - The bank loan money will be used to acquire a residential flat which is to be used by Mr Borrower as the Company's director. The loan will be guaranteed by Mr Borrower on a personal basis.

Loan E - The bank loan money will be used to purchase the Company's trading stock. Part of the bank loan will be sub-participated by another Hong Kong company which is also owned by Mr Borrower. The sub-participated portion of the loan will be secured by the original bank loan provided by the Company.

Required:

Applying the above tax principles, explain whether the interest incurred on loans A to E will be tax deductible for profits tax purposes.