When however collecting this information for the purpose of acquiring a certification of residence status for the Hong Kong company under the Hong Kong – Spain double taxation treaty, the obtained information is likely to be ignored by the HK IRD as it is irrelevant for the application of the relevant double taxation treaty.
On 29th of March 2012, the Hong Kong Inland Revenue Department (‘Inland Revenue’) finally released its Advance Pricing Arrangement (‘APA’) procedures in its Departmental Interpretation and Practice Notes no 48 (‘DIPN 48’). According to paragraph 1 of DIPN 48, the DIPN will provide guidance for companies willing to conclude an APA and explains its process,… Continue reading Advance Pricing Arrangement in Hong Kong and Mainland China
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