Whether enough tax substance in a Trust is present will always depend on the relevant facts of the case.
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 […]
Housing benefits received by directors/employees from employers or the employers’ affiliated corporations are generally subject to salaries tax in Hong Kong unless an offshore/exemption claim on their directors’ fees/employment income can be satisfied. However, the salaries tax can be potentially mitigated in most circumstances in case the housing benefits are provided in the form of […]
