Whether enough tax substance in a Trust is present will always depend on the relevant facts of the case.
On the 7th of June 2017, Mainland China on behalf of Hong Kong, signed the Multilateral Convention to Implement Tax Treaty Related Measures to prevent Base Erosion and Profit Shifting
Pursuant to the general charging provision of Section 14(1) of the Inland Revenue Ordinance (‘HK-IRO’), an income is NOT liable to profits tax (corporate income tax) if it is (i) not derived from a trade, profession or business carrying on in Hong Kong and/or (ii) not arising in or derived from Hong Kong (i.e. sourced […]
As a result of an increase of foreign investments in Mainland China and a strong demand for foreign talents by local Mainland Chinese companies, many foreigners are working nowadays either permanently or temporarily in Mainland China. These foreigners are advised to do proper ahead of time tax planning or revise their employment/assignment arrangements in Mainland […]
