Hong Kong Tax Treaty - HKWJ Tax Law

Hong Kong Tax Treaties: An Overview

As from the year of assessment 2014/2015, i.e. as from April 1st 2014, Hong Kong will have 28 unlimited double taxation treaties effectively in place (with Austria, Belgium, Brunei, Canada, Czech Republic, France, Guernsey, Hungary, Indonesia, Ireland, Japan, Jersey, Kuwait, Liechtenstein, Luxembourg, Mainland China, Malaysia, Malta, Mexico, the Netherlands, New Zealand, Portugal, Qatar, Spain, Switzerland, […]

Hong Kong Advance Pricing Arrangement Procedures Introduced

Advance Pricing Arrangement 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 […]

Judicial Independence and Judicial Autonomy

Why Judicial Independence and Judicial Autonomy in Hong Kong is still not a Broken Dream. A Divorced Mother Relationship and Comparative Analysis with the EU. Much has already been written about judicial independence and judicial autonomy in the Hong Kong Special Administrative Region (HKSAR) and its judicial referral system under the ambiguous ‘constitutional’ article 158(3) […]

Hong Kong Profits Tax & Aviation Fuel Supply Company v CIR

The charging provision of profits in Hong Kong, detailed in article 14 of the Inland Revenue Ordinance (IRO), might be considered as simple by ‘outsiders,’ it is far from straightforward, as the charging provision can be open to many different interpretations. As a result, even the most straightforward cases can prove complex, and interpretation is […]