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, […]

Advance Pricing Arrangement - HKWJ Tax Law

Advance Pricing Arrangement in Hong Kong and Mainland China

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, […]

securities and commodities trading and corporate tax profits tax - HKWJ Tax Law

Trading Securities and Commodities and Corporate Income

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 […]