Transfer pricing (“TP”) refers to the setting of prices for transactions of goods, services and intangible property between associated enterprises. Globalisation has increased the number of cross-border transactions between associated enterprises. This has also created opportunities for cross-border tax avoidance by taking advantage of differences in tax regimes across jurisdictions. This problem is commonly referred… read more
It is sometimes argued that a company incorporated under HK Law (“HK Co”) will (a) automatically be regarded as a Hong Kong tax resident for tax purpose; and (b) only be subject to profits tax in Hong Kong but not in other tax jurisdictions. However, one has to be well aware that if HK Co lacks… read more
What are they? Are they really dangerous? The more SAAR, the less GAAR? In Hong Kong, we are somehow in the very ‘luxurious’ position not to have only 1 General Anti-Avoidance Rule provision (“GAAR”), but even to have 2 GAAR provisions. The first GAAR provision can be found in section 61 of the Hong Kong… read more
Why you may want Advance Rulings on Tax? Advance rulings on tax, a kind of tax insurance, help to reduce the tax risks companies may face. This, as for most investors and their management, potential tax liabilities and tax risks that may arise within the company remains a concern when conducting their businesses. As… read more
When incorporating a Hong Kong company or registering a branch, one should take note of the so-called ‘BR Fee’ upon a business registration in Hong Kong. The BR Fee is a fee payable to the Inland Revenue Department of Hong Kong and either relates to a governmental fee for registering a business or a branch… read more
