There has been some lobbying going on by tax representative groups in Hong Kong saying that the HK IRD should liaise with its tax treaty partners to accept the standard “Certificate of Incorporation” (issued by the Hong Kong Company Registrar upon incorporation of a Hong Kong company) as the proof for a Hong Kong company […]
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, […]
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, […]
The question whether or not the profits including commissions arising out of securities and commodities trading are subject to Hong Kong corporate income tax have been subject to several Hong Court cases. In Nice Cheer Investment Limited v CIR (HCIA 8/2007), dated 28th of June 2011, were however the unrealised gains arising out of the […]
